Case Summary (G.R. No. 208738-39)
Factual Background
Raymundo B. Corpuz, employed by Citigroup as a Customer Solutions Officer since 2006, filed a complaint against his employer for illegal dismissal and other labor-related grievances. The case arose after Corpuz disclosed confidential customer information during a phone call, which led to disciplinary actions by Citigroup, including preventive suspension and ultimately dismissal. Citigroup contended that Corpuz's actions constituted serious misconduct due to the unauthorized disclosure of confidential information.
Labor Arbiter's Ruling
The Labor Arbiter initially dismissed Corpuz's complaint, ruling that his preventive suspension was justified under company policies regarding information security. The Arbiter concluded that Corpuz's disclosure was a serious misconduct that warranted dismissal and determined that due process had been observed in Citigroup's termination of Corpuz.
NLRC's Affirmation with Modification
Upon appeal, the National Labor Relations Commission modified the Labor Arbiter's ruling, asserting that while Corpuz's termination was valid, Citigroup had not sufficiently adhered to the procedural requirements of due process. The NLRC mandated Citigroup to pay nominal damages and his proportionate 13th-month pay while affirming the validity of the dismissal.
Court of Appeals' Decision
The Court of Appeals later reversed the NLRC's decision, declaring that Citigroup had illegally dismissed Corpuz. The court acknowledged the preventative measures taken by Citigroup but found that Corpuz's actions stemmed from a mistaken belief that he was assisting a legitimate customer inquiry involving an affiliate of Citigroup. The CA ruled that there was no serious misconduct justifying dismissal, and emphasized that the information disclosed was not strictly confidential as it could be publicly accessed.
Supreme Court's Ruling and Analysis
The Supreme Court upheld the CA's ruling, affirming that the dismissal was indeed illegal. It focused on the definition and elements of serious misconduct, emphasizing that for an act to constitute serious misconduct justifying dismissal, it must involve willful intent to violate policies. The court determined that Corpuz's mistaken belief in the legitimacy of the phone call showed no intent to harm Citigroup, aligning with precedents that emphasized the necessity of prov
...continue readingCase Syllabus (G.R. No. 208738-39)
Background of the Case
- Petition for Review on Certiorari under Rule 45 challenging the Court of Appeals decision.
- The case concerns illegal dismissal, illegal suspension, unfair labor practice, non-payment of salaries and 13th month pay, and moral damages claims.
- Respondent, Raymundo B. Corpuz, was employed as Customer Solutions Officer by Citigroup.
- At hiring, Corpuz signed a Privacy Promise Agreement and Confidential Information Agreement to safeguard customer and company information.
Factual Circumstances Leading to Dispute
- On July 3, 2007, Corpuz received a call from someone claiming to be a Metlife officer seeking assistance with an unclaimed check.
- Corpuz disclosed confidential customer information including name, address, account number, and phone numbers, and commented on the mortgage account status.
- The next day, Corpuz was confronted by his supervisor and issued a Show Cause Memorandum and placed under preventive suspension.
- Corpuz explained that he believed the caller was legitimate due to Metlife's affiliation with Citigroup.
Administrative Proceedings and Termination
- Investigation by Citigroup Security and administrative hearing were conducted.
- On August 6, 2007, Corpuz was informed of his termination due to breach of confidentiality policy.
- Corpuz requested reconsideration; however, suspension was extended with pay pending final decision.
- On August 17, 2007, termination was effectuated.
Claims and Defenses
- Corpuz filed a complaint for illegal dismissal, illegal suspension, unfair labor practice, unpaid salaries, 13th month pay, moral and exemplary damages, and attorney’s fees.
- Citigroup defended the dismissal citing unauthorized disclosure of confidential information as serious misconduct, willful disobedience, and breach of trust.
- Citigroup asserted violation of company policy and that the disclosed information was confidential financial data.
Labor Arbiter's (LA) Decision
- Dismissed illegal dismissal and suspension complaints for lack of merit but ordered pro-rata 13th month pay to Corpuz.
- Upheld preventive suspension as lawful due to risk of security breach.
- Found dismissal justified due to serious misconduct with sufficient opportunity afforded to Corpuz to be heard.
- Dismissed unfair labor practice claim for failure to prove employer's intent to restrain employees’ rights.