Case Summary (G.R. No. 200352)
Factual Antecedents
Mary June Celiz commenced her employment with Cord Chemicals, Inc. in 1992, eventually rising to the position of Chief of Sales. Following the death of Francisco Sanz, the former owner and her alleged paramour, Celiz faced dismissal purportedly due to unliquidated cash advances amounting to P713,471.00. She claimed that her dismissal was motivated by jealousy from Leonor Sanz and that the allegations of financial misconduct were fabricated. Despite Celiz's attempts to resign amicably, she was dismissed for failing to account for these advances.
Employment Dispute
Celiz's dismissal was preceded by a notice to explain her failure to liquidate advances, leading to preventive suspension. Following an internal audit revealing significant discrepancies in her financial management, she was officially dismissed on December 6, 2008. Celiz contested the dismissal through labor litigation, claiming illegal dismissal and asserting that the charges against her were unfounded.
Proceedings Before Labor Arbiter
Celiz’s claim of illegal dismissal was initially dismissed by the Labor Arbiter, who concluded that there was just cause for termination based on a serious breach of trust and confidence. The decision highlighted that as a managerial employee, she was obligated to handle funds with utmost integrity, and her failure to liquidate the cash advances constituted misconduct justifying her dismissal.
Appeal to the NLRC
Celiz elevated her case to the National Labor Relations Commission (NLRC), which upheld the Labor Arbiter's ruling. The NLRC found no grounds for reconsideration, endorsing the Labor Arbiter’s findings of procedural compliance and substantial evidence backing the dismissal.
Court of Appeals Ruling
Celiz subsequently filed a petition for certiorari with the Court of Appeals, which also affirmed the NLRC's decision. The Court emphasized the compelling evidence demonstrating Celiz’s breach of trust and her inadequate defense against the claims of unliquidated cash advances. It reiterated that loss of trust and confidence does not require proof beyond a reasonable doubt but rather a reasonable basis for believing the employee’s misconduct.
Key Legal Principles
The decision accentuates the principle that employers must demonstrate a reasonable ground for dismissal based on trust loss, particularly for managerial employees. The jurisprudence also articulates that proced
...continue readingCase Syllabus (G.R. No. 200352)
Case Information
- G.R. No.: 200352
- Date: July 20, 2016
- Division: Second Division
- Decision by: Justice Del Castillo
Background of the Case
- This case involves a Petition for Review on Certiorari challenging the October 26, 2011 Decision of the Court of Appeals (CA), which dismissed Celiz's Petition for Certiorari in CA-G.R. SP No. 116098, and the subsequent January 18, 2012 Resolution denying her Motion for Reconsideration.
Factual Antecedents
- Cord Chemicals, Inc. (Cord, Inc.): A domestic company owned by Leonor Sanz, the Chief Executive Officer.
- Employment of Celiz: Celiz began her career with Cord, Inc. in 1992 as an Assistant Accounting Manager, eventually being promoted to Chief of Sales and Senior Operations Manager.
- Alleged Misconduct: Following the death of Francisco Sanz (Leonor's husband) in 2008, Celiz was reportedly dismissed for failing to account for unliquidated advances totaling P713,471.00.
- Preventive Suspension: Cord, Inc. placed Celiz on preventive suspension after she was accused of dishonest handling of company funds due to her failure to liquidate cash advances.
- Claim of Dismissal: Celiz claimed her dismissal was unjust and filed for illegal dismissal and monetary benefits before the Labor Arbiter.
Proceedings Before Labor Arbiter
- Defense from Cord, Inc.: The company denied the charges of illegal dismissal and asserted that Celiz was aware of her unliquidated cash advances. They provided evidence, including letters from Celiz to Francisco declaring her affection.
- Decision