Case Summary (G.R. No. 193219)
Summary of Events
Domrique and LeaAo commenced their employment in February 1993 and January 1996, respectively. Their roles included operating photocopy machines and managing customer payments. On October 12, 2005, LeaAo, with fellow employee Grace Lorenzo, lodged a complaint with the Department of Labor and Employment (DOLE) regarding labor standards violations by their employer. An inspection by a DOLE Labor Inspector subsequently revealed several violations, prompting management to conduct an internal audit, which uncovered discrepancies in the meter readings associated with the photocopying machines handled by the respondents.
Allegations and Immediate Consequences
Following the audit, the petitioners accused the respondents of collaborating to falsify the meter readings to cover up their alleged misappropriation of funds. On November 4, 2005, both respondents received termination letters citing defrauding the company as the reason for their dismissal. The respondents contended that their dismissals were unfounded and that they had not been afforded the opportunity to explain or defend themselves against the allegations before termination.
Administrative Proceedings
On November 9, 2005, Domrique and LeaAo filed separate complaints with the National Labor Relations Commission (NLRC) asserting illegal dismissal and money claims, arguing the absence of due process in their termination. The Labor Arbiter ruled in favor of the respondents on February 28, 2006, stating that the petitioners failed to comply with procedural due process norms and lacked sufficient evidence to confirm their allegations.
NLRC Decisions and Appeals
Petitioners appealed the Labor Arbiter's decision to the NLRC, which initially affirmed the ruling on February 12, 2008. However, following a motion for reconsideration, the NLRC reversed itself on May 29, 2009, concluding that the respondents’ actions constituted admission of wrongdoing. This decision, however, faced a challenge when the respondents sought certiorari from the Court of Appeals (CA), which reinstated the Labor Arbiter's decision on February 16, 2010, declaring the dismissal illegal.
Supreme Court Proceedings
The petitioners, dissatisfied, brought their case to the Supreme Court, arguing that the CA misapprehended the facts and law regarding the basis for dismissal. The Court scrutinized the evidence presented by the petitioners and determined that the documents submitted, which were interpreted as confessions of guilt, did not substantiate the claims of theft or misappropriation against the respondents
...continue readingCase Syllabus (G.R. No. 193219)
Case Background
- The petition for review on certiorari under Rule 45 of the Rules of Court challenges the Decision of the Court of Appeals (CA) dated February 16, 2010, and its Resolution dated July 20, 2010, in CA-G.R. SP No. 110614.
- Respondents Marilyn Domrique and Carina LeaAo were employed as photocopy machine operators by petitioners starting on February 21, 1993, and January 1996, respectively, at their branch in Laoag City.
- Domrique received a daily salary of P145.00 (or P200.00 with an allowance) and LeaAo received P120.00 daily. Both earned 7% of the branch's total earnings monthly and were provided with free board.
Allegations of Misconduct
- Domrique handled one liquid and one powder photocopying machine, while LeaAo managed a liquid photocopier and collected customer payments from October 1-31, 2005.
- On October 12, 2005, LeaAo and colleague Grace Lorenzo filed a formal complaint with the Department of Labor and Employment (DOLE) regarding labor standards violations by petitioners.
- Following a DOLE inspection on October 18, 2005, violations such as underpayment of wages, 13th month pay, and overtime were noted.
Audit and Termination
- On November 2, 2005, Susana Montano, the manager and wife of petitioner Virgilio Montano, audited the branch and discovered discrepancies in meter readings submitted by respondents.
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