Case Summary (G.R. No. 211522)
Facts of the Case
Fernando S. Iguiz was employed by J' Marketing Corporation (JMC) starting September 1995, initially as a driver and later promoted to collector/credit investigator. On 11 December 2006, JMC identified a shortage of P5,811 in Iguiz’s cash remittance for the previous week, prompting a memorandum from branch manager Pepito Estrellan requiring Iguiz to explain the discrepancy. Iguiz attributed the shortage to a loss caused by flood during Typhoon "Siniang" and proposed remittance of the missing amount in his reply while stating he had lost it. An audit conducted in February 2007 revealed additional unremitted amounts from prior months.
Administrative Investigation
Following the audit findings, Estrellan issued a memorandum on 8 February 2007, leading to an administrative investigation where Iguiz was asked to explain why he should not be reprimanded for trust breach due to unremitted collections. Accusations included collecting P15,300 and $29 from customers without issuing official receipts. Despite his denial and an explanation referencing the absence of complaints from any customers, JMC proceeded with the investigation. Iguiz was notified of his termination on 7 March 2007 for dishonesty and breach of trust under the Labor Code.
Proceedings Before the Labor Arbiter
Iguiz challenged his dismissal by filing a complaint for illegal dismissal with the National Labor Relations Commission (NLRC). The Labor Arbiter dismissed his complaint, finding that his unsubstantiated denial of the allegations justified dismissal based on loss of trust.
Appeal to the NLRC
Dissatisfied with the Labor Arbiter's decision, Iguiz appealed to the NLRC, which reversed the ruling, declaring his dismissal illegal. The NLRC held that JMC failed to provide sufficient evidence of dishonesty or just cause for the termination, highlighting the lack of proper administrative process.
Court of Appeals Decision
JMC sought to contest the NLRC’s ruling in the Court of Appeals, which upheld the NLRC’s decision citing that JMC did not present substantial evidence to support the claims against Iguiz. The CA emphasized the absence of transactional details in the allegations and pointed out that no complaints were filed by affected customers, undermining the basis for termination.
Supreme Court’s Ruling
The Supreme Court maintained the decisions of both the NLRC and the CA, concluding that the
...continue readingCase Syllabus (G.R. No. 211522)
The Case
- This case is a petition for review on certiorari challenging the Decision dated 16 July 2013 and the Resolution dated 30 January 2014 of the Court of Appeals (CA) in CA-G.R. SP No. 04657.
- The case involves the employment termination of Fernando S. Iguiz, who was dismissed by J' Marketing Corporation (JMC) for alleged dishonesty and breach of trust.
The Facts
- Fernando S. Iguiz was employed by JMC as a driver in September 1995 and later promoted to a collector/credit investigator.
- On 11 December 2006, Iguiz submitted a Daily Cash Collection Report but was found to be short in remittances by P5,811, allegedly due to a flood caused by Typhoon "Siniang."
- Following the discovery of the shortfall, Iguiz was suspended and requested to explain the shortage.
- In his response, he tendered the missing amount and cited the flood as an explanation.
- JMC later conducted an audit revealing further unremitted collections amounting to P15,300 and $29 from 14 customers without official receipts.
- Iguiz was subsequently asked to explain why he should not be reprimanded for loss of trust and confidence.
- An administrative investigation was conducted without Iguiz's acknowledgment, and he was later terminated on 7 March 2007 for dishonesty and breach of trust.
Procedural History
- Iguiz filed a complaint for illegal dismissal with the National Labor Relations Commission (NLRC), which was initially dismissed by the Labor Arbiter fo