Case Summary (G.R. No. 188035)
Facts Leading to Dismissal
The dismissal resulted from allegations of financial irregularities involving the school cashier, Janice Loba, which were uncovered during an audit prompted by a complaint from a student's parent regarding issues with payment documentation. The audit conducted by ICA's Internal Auditor revealed substantial unaccounted collections amounting to approximately P1,167,181.45, as well as manipulated records and missing official receipts, which raised concerns regarding Camilon's oversight of the financial operations within her department.
Suspension and Termination Process
Following the audit, on September 1, 2004, Campos suspended Camilon pending investigation, during which she denied any wrongdoing. Subsequently, on October 27, 2004, she was terminated for gross negligence and for failing to adequately supervise the cash department, despite her claims to the contrary.
Legal Proceedings and Initial Decisions
On November 26, 2004, Camilon filed a complaint for illegal dismissal against ICA and Campos. The Labor Arbiter ruled in favor of Camilon, declaring her dismissal illegal due to the lack of substantial evidence for the charges against her and for procedural lapses, such as inadequate notice of the termination grounds.
NLRC and CA Rulings
The National Labor Relations Commission (NLRC) later reversed the Arbiter's decision, finding Camilon's dismissal and suspension to be legal while still ordering payment for her unpaid salaries and other benefits accrued prior to termination. The NLRC emphasized the extent of Camilon's negligence as justification for her termination.
The Court of Appeals (CA) upheld the NLRC's findings but modified the decision by awarding separation pay to Camilon, arguing that her long tenure at the institution warranted such an award despite the lawful basis for her dismissal.
Petitioner's Arguments Against Separation Pay
The petitioners challenged the CA's decision, arguing that separation pay should not be awarded due to the nature of Camilon's dismissal for gross and habitual negligence. They contended that such misconduct should negate any entitlement to separation pay, regardless of service length.
Supreme Court's Analysis
The Supreme Court analyzed whether the CA’s grant of separation pay was appropriate, referencing the established principle that employees who are dismissed for just causes, particularly thos
...continue readingCase Syllabus (G.R. No. 188035)
Background of the Case
- The case involves a petition for review on certiorari filed by petitioners Immaculate Conception Academy (ICA) and Dr. Jose Paulo E. Campos against respondent Evelyn E. Camilon.
- The petition seeks to reverse the March 30, 2009 Decision and May 25, 2009 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 105166.
- The CA affirmed the February 29, 2008 Decision of the National Labor Relations Commission (NLRC), which found that Camilon was validly dismissed but held petitioners liable for her separation pay as a measure of social justice.
Parties Involved
- Petitioners:
- Immaculate Conception Academy (ICA), an educational corporation in Dasmariñas, Cavite.
- Dr. Jose Paulo E. Campos, President of ICA.
- Respondent:
- Evelyn E. Camilon, former Chief Accountant and Administrator of ICA, employed for 12 years.
Factual Antecedents
- Camilon served as Chief Accountant from June 2000 until her dismissal in October 2004.
- A complaint was filed in July 2004 regarding the denial of an examination permit to a student due to nonpayment of tuition, despite claimed payment.
- An audit conducted by ICA's Internal Auditor in August 2004 revealed:
- Unaccounted payments from 186 students totaling P1,167,181.45.
- Missing official receipts and manipulated records by the school cashier, Janice C. Loba.
- Camilon was suspended on September 1, 2004, pending investigation.
- After be