Case Summary (G.R. No. 123737)
Events Leading to Suspension
On August 3, 1993, Libres received a notice from Hynson requiring a written explanation regarding a charge of sexual harassment brought against him by Susan D. Capiral, Hynson's secretary. The alleged harassment occurred in May 1992. Libres submitted his explanation on August 14, 1993, denying the charges, and participated in an internal investigation conducted by Hynson. Following this investigation, the Management Evaluation Committee (MEC) concluded that Libres violated the company's rules by engaging in inappropriate conduct with Capiral, which warranted a thirty-day suspension.
Administrative Actions and Complaints
Libres sought reconsideration of his suspension order in January 1994, but his request was denied. After the suspension was enforced on February 12, 1994, he filed a complaint against NSC and the individual respondents before the Labor Arbiter, alleging illegal suspension and denial of due process. The Labor Arbiter, however, ruled that due process was observed and upheld the MEC’s findings of sexual harassment.
Petitioner's Arguments
In his petition, Libres contended that the National Labor Relations Commission (NLRC) grievously erred in affirming his suspension based on an alleged lack of due process and misapplication of the law. He specifically highlighted the NLRC's failure to consider Republic Act No. 7877, which defines unlawful sexual harassment and argues that his actions did not satisfy the criteria set forth in this law.
Due Process Considerations
Libres argued that he was denied an opportunity for personal confrontation during the investigation process. However, the Labor Arbiter indicated that due process was adequately fulfilled through notification of the charges against Libres, his opportunity to submit a written defense, and requests for reconsideration. The court noted that due process does not require formal trial-type proceedings.
NLRC's Findings and Legal Context
The NLRC supported the Labor Arbiter’s conclusion that Libres committed acts of sexual harassment and did not find any basis for Libres' claims of procedural inadequacy. The court emphasized that findings of fact by administrative agencies like the NLRC are generally upheld barring clear evidence of grave abuse of discretion.
Legislative Applicability and Case Precedents
The court noted that RA No. 7877 was not yet
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Case Background
- The case involves a petition for certiorari filed by Carlos G. Libres against the National Labor Relations Commission (NLRC) and other respondents including National Steel Corporation (NSC) and its officials.
- The petition seeks to annul the NLRC’s decision, which upheld the Labor Arbiter’s finding that Libres was validly suspended from his position due to sexual harassment charges.
Parties Involved
- Petitioner: Carlos G. Libres, an electrical engineer and Assistant Manager at National Steel Corporation.
- Respondents: National Labor Relations Commission, National Steel Corporation, Osmundo G. Waga Jr., Antoine D. Seva, Peter J. Loquillano, Saturnino P. Mejorada, and Isidro F. Hynson Jr.
Factual Background
- On August 3, 1993, Libres received a Notice of Investigation from his superior, Isidro F. Hynson Jr., regarding allegations of sexual harassment made by Susan D. Capiral, a secretary.
- The allegations pertained to incidents occurring in May 1992, where Libres allegedly touched Capiral inappropriately.
- Libres submitted a written explanation denying the accusations and offered to answer questions.
- An internal investigation was conducted by Hynson Jr., leading to a report submitted to the Management Evaluation Committee (MEC).
Findings of the Management Evaluation Committee (MEC)
- The MEC concluded that Libres’ actions constituted sexual harassment, which violated Item 2, Table V of the Plant's Rules and Regulations.
- The MEC recommended a