Case Summary (G.R. No. L-70479)
Background of the Case
Carlos Lariosa commenced his employment with Firestone on January 3, 1972, ultimately assuming the role of a tire builder. On July 27, 1983, during a standard security check at the company’s premises, Lariosa was found in possession of sixteen flannel swabs belonging to the company, hidden in his personal bag. This discovery led to his dismissal on August 2, 1983, on the grounds of "stealing company property and loss of trust." Subsequently, Firestone filed a criminal complaint against him for attempted theft.
Proceedings Before the Labor Arbiter and NLRC
In response to his dismissal, Lariosa filed a complaint against Firestone for illegal dismissal and claimed violations of labor laws and damages. The Labor Arbiter ruled on May 8, 1984, affirming the validity of Lariosa's dismissal. However, upon appeal, the NLRC overturned the Arbiter's decision on December 28, 1984, citing that the dismissal was excessively severe and ordering Lariosa's reinstatement without backwages, treating the duration of his absence as a suspension.
Issues Raised by Petitioner
Firestone challenged the NLRC's decision through a petition for certiorari, claiming that the NLRC had committed grave abuse of discretion by accepting Lariosa's appeal despite its late filing. Firestone contended that Lariosa was afforded due process, and therefore the Commission's reversal of the Labor Arbiter's ruling was unjustified.
Appellate Lapses and Legal Interpretation
Lariosa's appeal, filed on June 7, 1984, was indeed late according to Article 223 of the Labor Code, which stipulates a ten-day reglementary period for such appeals. However, considering potential misleading guidance regarding this timeframe and the intent of the law to protect employee rights, the Supreme Court expressed a willingness to overlook this procedural lapse in order to address the merits of the case.
Findings on the Alleged Misconduct
The investigation revealed substantial evidence of Lariosa's involvement in the attempted theft. Testimonies from security personnel contradicted Lariosa's defense, revealing inconsistencies in his claims regarding the flannel swabs. Firestone's actions, which included conducting a thorough investigation and timely issuing a dismissal notice, indicated adherence to legal procedures and was deemed justifiable under allegations of serious misconduct.
Judicial Conclusion on Grounds for Dismissal
The Supreme Court affirmed that theft, particularly by an employee entrusted with company property, constitutes valid grounds for termination. The ruling emphasized that dishonesty in handling company property undermines the employer’s trust, thereby warranting di
...continue readingCase Syllabus (G.R. No. L-70479)
Case Background
- The case involves a petition for certiorari filed by Firestone Tire and Rubber Company of the Philippines (hereinafter referred to as "Firestone") against Carlos Lariosa and the National Labor Relations Commission (NLRC).
- The petition challenges the NLRC's decision that ordered the reinstatement of Lariosa, a dismissed tire builder, without backwages, asserting that the NLRC acted with grave abuse of discretion.
Facts of the Case
- Carlos Lariosa began his employment with Firestone on January 3, 1972, and was working as a tire builder at the time of his dismissal.
- On July 27, 1983, Lariosa was subjected to a routine security check by guards at the company premises, during which sixteen wool flannel swabs belonging to Firestone were discovered in his personal bag.
- Following this incident, Firestone terminated Lariosa's employment on August 2, 1983, citing theft of company property and loss of trust as the grounds for dismissal.
- Lariosa subsequently filed a complaint for illegal dismissal and damages against Firestone, while the company also pursued a criminal complaint for attempted theft.
Decisions of the Labor Arbiter and NLRC
- The Labor Arbiter ruled on May 8, 1984, that Lariosa's dismissal was justified.
- Lariosa appealed the decision, and on December 28, 1984, the NLRC revers