Case Summary (G.R. No. 128617)
Dismissal of Employees for Theft
The case centers around the dismissal of the three employees for alleged qualified theft of crude oil. On April 29, 1977, land guards from Dole Philippines reported finding two drums of crude oil near the company's farmlot. Subsequent investigations revealed that Tarroza, De la Pena, and Tejero allegedly sold crude oil to local farmers, implicating them in theft from company property. The employees were suspended while facing criminal charges for these actions.
Labor Arbiter's Decision
Following an application by Dole Philippines to terminate the employees for "stealing or dishonesty," the Regional Office of the Department of Labor granted the company clearance to dismiss the workers. Later, on October 17, 1978, the Labor Arbiter dismissed the employees' complaint for illegal dismissal, affirming the validity of their termination based on the statements of the buyers who implicated them.
NLRC Ruling and Reversal
The employees appealed to the NLRC, presenting affidavits from Asibal and Odarve, which recanted their previous statements. The NLRC found that Dole Philippines failed to conduct an adequate investigation before termination and ordered the employees' reinstatement with back wages on September 5, 1980.
Supreme Court’s Evaluation of Legal Standards
The Supreme Court evaluated the legal standards governing employee termination under the Labor Code, particularly focusing on Article 283, which permits termination for serious misconduct or loss of trust. The Court determined that an employer may terminate employment based on loss of confidence without requiring proof beyond a reasonable doubt. The Court noted that the circumstances surrounding the employees’ involvement justified Dole Philippines' actions despite the subsequent criminal acquittal.
Affidavits of Recantation
The Court further addressed the affidavits of recantation from Asibal and Odarve, concluding that these did not sufficiently exonerate the employees nor negate their involvement in the theft, as they did not claim that they did not purchase oil from the dismissed employees. Consequently, the Court acknowledged Dole Philippines' right to terminate the respondents based on the company's concerns about trust, considering the nature of their employment and access to company assets.
No Requirement for Company Investigation
Dole Philippines was not obligated to conduct its own investigation into the theft because it had immediately reported the matter to law enforcement, which the Court presumed acted according
...continue readingCase Syllabus (G.R. No. 128617)
Case Overview
- This case involves a special civil action for certiorari concerning the dismissal of three employees of Dole Philippines, Inc. (Dolefil) for the alleged offense of qualified theft of crude oil.
- The dismissed employees—Alfredo Tarroza, Rogelio De la Pena, and Loreto Tejero—were light-wheel tractor operators in Dolefil's pineapple fields in Polomolok, South Cotabato.
- Their employment was terminated following their alleged involvement in siphoning diesel fuel from the tractors they operated.
Facts of the Case
- On April 29, 1977, landguards from Dolefil discovered two drums of crude oil on the property of Inocencio Asibal, adjacent to the Dolefil fields.
- The discovery led to an investigation by the police, during which Asibal and his companion, Rogelio Odarve, admitted to purchasing crude oil from the three dismissed employees and two other Dolefil workers.
- In sworn statements, Asibal indicated he bought crude oil from Tarroza and Tejero on separate occasions. Odarve also claimed he purchased crude oil from De la Pena.
- Dolefil then filed for clearance to terminate the employees due to "stealing or dishonesty" and suspended them effective May 13, 1977.
- The labor authority granted Dolefil clearance to terminate the employees o