Case Summary (G.R. No. 211105)
Background of Employment
Del Rosario began her tenure at CW Marketing in 2007 and progressed to the role of Sales Supervisor at the Home Depot, Balintawak Branch. As part of her duties, she was assigned a computer with shared access to a printer/scanner, in which she was the sole employee trained on its operation.
Investigation and Initial Allegations
The situation unraveled in October 2010 when HSBC reported the submission of falsified payslips and identification cards by applicants allegedly associated with CW Marketing. Following an investigation initiated by CW Marketing's IT Department, Del Rosario received a Notice to Explain through which she was asked to clarify her involvement in the alleged falsifications linked to her computer.
Del Rosario's Responses
In her responses to the notices, particularly on November 5 and November 10, 2010, Del Rosario admitted to allowing her subordinates access to her computer but denied any direct participation in the falsifications of documents. She emphasized that other individuals had access to the computer and were responsible for the actions in question, asserting her lack of involvement in any misconduct.
Administrative Inquiry and Termination
An administrative inquiry was held on November 18, 2010, where Del Rosario acknowledged her accountability regarding the computer assigned to her. Consequently, CW Marketing terminated her employment on November 30, 2010, citing multiple violations of the company handbook, including negligence and misuse of company property.
Legal Proceedings
Del Rosario filed a complaint for illegal dismissal, among other claims, at the NLRC. Initially, the Labor Arbiter ruled in her favor, asserting that CW Marketing did not establish that Del Rosario directly committed falsification. However, upon appeal, the NLRC reversed this decision, finding sufficient grounds for Del Rosario's dismissal based on loss of trust and confidence, especially given her supervisory role.
Court of Appeals Ruling
Del Rosario subsequently challenged the NLRC's ruling in the Court of Appeals. The appellate court affirmed the NLRC's decision, agreeing that Del Rosario's negligence in supervising the use of her assigned computer justified her dismissal.
Supreme Court Decision
Del Rosario's petition for certiorari reached the Supreme Court, where it was denied, reinforcing the earlier findings from the NLRC and CA. The Court emphasized that loss of trust and confidence can serve as a valid cause for dismissal, particularly for employees in positions of responsibility. The Court supported the conclusion that Del Rosario's actions demonstrated negligence and a failure to appropriately supervise her subordinates, actions that compromised the company's integ
...continue readingCase Syllabus (G.R. No. 211105)
Case Overview
- Petitioner Ruby C. Del Rosario (Del Rosario) appeals the Decision dated October 9, 2013, of the Court of Appeals (CA) in CA-G.R. SP No. 126846, which upheld the National Labor Relations Commission (NLRC) Decision dated June 6, 2012.
- The NLRC dismissed Del Rosario's complaint for illegal dismissal against respondents CW Marketing & Development Corporation (CW Marketing) and Mr. Kenneth Tung.
Background of Employment
- Del Rosario was employed by CW Marketing since 2007, starting as a Sales Consultant and later becoming a Sales Supervisor at the Home Depot, Balintawak Branch.
- She was assigned a computer connected to a shared network and printer/scanner, and was the sole employee trained by CW Marketing's IT personnel to operate the machine.
Allegations of Document Falsification
- In October 2010, CW Marketing received a report from HSBC regarding falsified payslips and identification cards submitted by individuals applying for credit cards.
- An investigation by CW Marketing's IT Department revealed that these documents were obtained from Del Rosario's computer.
- On November 4, 2010, CW Marketing issued a Notice to Explain to Del Rosario, requiring her to clarify her alleged involvement in the falsification.
Del Rosario's Response
- In her email response dated November 5, 2010, Del Rosario acknowledged knowing the individuals involved but denied participating in the falsification.
- She claimed that other employees used her computer and th