Case Summary (G.R. No. 215314)

Employer's Management Prerogative

• The Court emphasizes the right of employers to exercise management prerogatives, including the dismissal of erring employees.
• Labor law discourages interference with an employer's judgment in business conduct.
• Employers' actions must be in good faith to advance their interests and not to undermine employees' rights.

Case Background

• The case involves a petition for review challenging the Court of Appeals' decision affirming the National Labor Relations Commission's (NLRC) ruling regarding the dismissal of Zuelo Apostol.
• Apostol was employed by Central Azucarera de Bais (CAB) for 20 years as a Motor Pool Over-All Repairs Supervisor.
• His employment was disrupted when it was discovered he used company resources to repair personal vehicles.

Incident Leading to Dismissal

• On February 2, 2002, a security guard reported Apostol for using company equipment and housing for personal vehicle repairs.
• A memorandum was issued to Apostol, requiring him to explain his actions and placing him on preventive suspension.
• Apostol submitted a handwritten apology acknowledging his violation of company rules.

Termination and Subsequent Complaint

• Apostol received a termination letter on February 9, 2002, and subsequently filed a complaint against CAB for various labor-related grievances.
• The complaint included claims of constructive dismissal, illegal suspension, and underpayment of wages.

Labor Arbiter's Ruling

• The Labor Arbiter dismissed Apostol's complaint, stating:
  • Allegations of unfair labor practice were unsubstantiated.
  • CAB had the right to impose preventive suspension.
  • Apostol violated company rules, and due process was followed.

NLRC's Reversal of Labor Arbiter's Decision

• The NLRC reversed the Labor Arbiter's ruling, stating:
  • Apostol was not given a proper hearing.
  • His remorse indicated no serious misconduct.
  • Dismissal was too severe for the violation committed.

Court of Appeals' Affirmation

• The Court of Appeals upheld the NLRC's decision, asserting:
  • CAB complied with notice requirements.
  • Apostol's violation was not grave enough to warrant dismissal.

Petitioners' Arguments

• CAB challenged the CA's decision on several grounds:
  • Procedural and substantive due process were observed in Apostol's termination.
  • The penalty was appropriate given the violation.
  • Apostol was not entitled to backwages or separation pay due to just cause for dismissal.

Court's Ruling on Procedural Due Process

• The Court found merit in the petitioners' arguments, emphasizing:
  • Only questions of law are reviewable; factual findings by labor tribunals are respected.
  • The Labor Arbiter and CA correctly found that CAB complied with procedural due process.

Analysis of Substantive Due Process

• The Court agreed with the findings that Apostol violated company rules.
• The critical issue was whether the violation warranted dismissal.
• The Court concluded that the dismissal was justified based on Apostol's position of trust and the nature of his violation.

Justification for Dismissal

• The Court reiterated that employers have the right to dismiss employees for loss of trust and confidence, especially for those in positions of responsibility.
• Apostol&#...continue reading