Case Summary (G.R. No. 211522)

Case Overview

• This case involves a petition for review on certiorari challenging the decisions of the Court of Appeals regarding the illegal dismissal of Fernando S. Iguiz from J' Marketing Corporation (JMC).
• The case centers on allegations of dishonesty and breach of trust against Iguiz, who was employed as a collector/credit investigator.

Employment Background

• Fernando S. Iguiz was hired by JMC in September 1995 and was promoted to collector/credit investigator after nine months.
• On December 11, 2006, Iguiz reported a cash collection shortfall of P5,811, which he attributed to a flood caused by Typhoon "Siniang."

Initial Allegations and Response

• Following the shortfall, JMC suspended Iguiz and requested an explanation, to which he responded with a notarized letter and tendered the missing amount.
• JMC did not pursue further investigation at that time but later conducted an audit revealing additional unremitted collections totaling P15,300 and $29 from various customers.

Administrative Investigation

• On February 8, 2007, JMC issued a memorandum to Iguiz regarding the unremitted collections, asking for an explanation.
• An administrative investigation was conducted, but Iguiz claimed he was not given a fair opportunity to defend himself.

Termination of Employment

• On March 7, 2007, JMC terminated Iguiz's employment, citing dishonesty and breach of trust as grounds for dismissal.
• The termination notice referenced both the unremitted collections and the earlier shortfall of P5,811.

Legal Proceedings

• Iguiz filed a complaint for illegal dismissal with the National Labor Relations Commission (NLRC), which initially dismissed his complaint.
• Upon appeal, the NLRC reversed the Labor Arbiter's decision, declaring Iguiz's dismissal illegal and awarding him backwages, separation pay, and damages.

Court of Appeals Decision

• JMC's appeal to the Court of Appeals was denied, affirming the NLRC's decision.
• The appellate court found that JMC failed to provide substantial evidence to justify the dismissal and did not adhere to procedural due process.

Legal Standards for Dismissal

• The Labor Code requires both substantive and procedural due process for employee dismissal.
• Substantive due process necessitates a just cause for termination, while procedural due process requires the employee to be given a fair opportunity to be heard.

Findings on Substantial Evidence

• The Court noted that JMC did not present sufficient evidence to support the claims against Iguiz.
• The affidavits from customers were obtained belatedly, and no formal complaints were filed against Iguiz.

Procedural Due Process Violations

• JMC's actions were deemed to violate the procedural due process requirements, including insufficient ...continue reading