Case Summary (G.R. No. 238347)
Antecedent Facts
Melvin C. Ang was initially employed as an IT Specialist at IBM Solution Delivery, Inc., where he developed a Business Planning and Consolidation System for ICTSI. Following an informal job offer, Ang resigned from IBM and joined ICTSI on January 7, 2013. By June 2013, he was appointed the overall SAP BPC Administrator and later became involved in the Consolidation Team. After taking leave on February 28 and March 3, 2014, Ang received a notice of preventive suspension on March 4, 2014, detailing violations and incompetence.
Events Leading to Termination
Ang's response to the notice indicated that he believed his absence was approved and he argued against the allegations of his poor performance, attributing delays to user error rather than his negligence. Following a series of administrative hearings, Ang’s suspension was extended, ultimately leading to his dismissal on June 26, 2014, which was executed following claims of serious misconduct and insubordination.
Complaint for Illegal Dismissal
On September 23, 2014, Ang filed a complaint for illegal dismissal and related claims before the National Labor Relations Commission (NLRC). He asserted that his termination was unjust and that he had fulfilled his duties. Conversely, ICTSI defended the termination as being in compliance with procedural requirements, arguing Ang's dismissibility was warranted due to his unauthorized absences and poor performance.
Labor Arbiter's Decision
The Labor Arbiter ruled in favor of ICTSI, dismissing Ang’s complaints and upholding the legality of his dismissal based on valid grounds. The Arbiter noted ICTSI’s managerial prerogative to terminate an employee based on serious misconduct and lack of trust.
NLRC Ruling
Upon appeal, the NLRC partially reversed the Arbiter's decision, stating that Ang had been illegally dismissed. It ruled that the initial grounds for dismissal were insufficient and found that Ang had not received proper procedural due process. The NLRC ordered ICTSI to pay Ang backwages, separation pay, and attorney’s fees.
Court of Appeals Decision
Both parties appealed the NLRC's ruling. The Court of Appeals affirmed the NLRC’s decision, modifying the calculation dates for monetary awards but rejecting full backwages and further monetary claims. The appeals from both parties regarding this decision were subsequently filed.
Supreme Court Analysis
The Supreme Court reviewed the grounds for dismissal and determined that ICTSI had adequate cause to terminate Ang’s employment based on both gross neglect of duty and breach of trust, consistent with the criteria for validating dismissals based on loss of trust for managerial positions. It highlighted that Ang's role required substantial trust du
...continue readingCase Syllabus (G.R. No. 238347)
Case Overview
- The case involves two consolidated petitions for review on certiorari under Rule 45 of the Rules of Court.
- The petitions seek to annul and set aside the Consolidated Decision of the Court of Appeals (CA) dated November 9, 2017, and its Resolution dated March 22, 2018.
- The primary parties involved are Melvin C. Ang (the respondent in G.R. No. 238347) and International Container Terminal Services, Inc. (ICTSI), along with other individuals associated with ICTSI.
Antecedent Facts
- Melvin C. Ang was employed by IBM Solution Delivery, Inc. as an I.T. Specialist and was later assigned to ICTSI to develop a Business Planning and Consolidation System (SAP BPC).
- Ang received an informal job offer from ICTSI in November 2012 and officially joined on January 7, 2013.
- Ang was designated as the overall SAP BPC Administrator in June 2013 and was part of the ICTSI Consolidation Team.
- After requesting a leave of absence, Ang returned to find he had been placed under preventive suspension due to alleged violations, including unauthorized absences and failure to complete assigned tasks.
Issues Raised by Ang
- Ang contended that the notice of suspension was unsigned and questioned his absence, claiming he had informed his superior.
- He argued that errors in task c