Case Summary (G.R. No. 163788)
Facts of the Case
Ester B. Maralit was employed by the Philippine National Bank from August 27, 1968, until December 31, 1998, during which time she ascended from casual clerk to branch manager. In February 1998, PNB offered an early retirement plan, the Special Separation Incentive Plan (SSIP), which allowed personnel involved in pending administrative cases to apply, with payment contingent on the resolution of their cases. An Internal Audit Group memorandum on September 8, 1998, indicated that Maralit had violated bank policies, resulting in the return of checks worth P54,950,000. Subsequently, PNB charged Maralit with serious misconduct and placed her under preventive suspension.
Administrative Proceedings
Maralit submitted her early retirement application on September 15, 1998, while facing these charges. On November 20, 1998, PNB conditionally approved her retirement, stating that payment for her benefits would occur only after resolving her administrative case. The Internal Audit recommended Maralit provide a written explanation regarding the charges against her. Ultimately, on April 14, 2000, PNB dismissed Maralit from service for serious misconduct, with her retirement benefits forfeited.
Labor Arbiter's Ruling
In a ruling dated January 22, 2001, the Labor Arbiter found Maralit entitled to P1,359,086.02 in retirement benefits and awarded her damages for her wrongful dismissal, noting that she was not under a preliminary investigation at the time of her retirement application, which denied her due process.
NLRC's Ruling
The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's ruling in a modified form on August 27, 2001, deleting the award for exemplary damages while maintaining Maralit's entitlement to retirement benefits. PNB then filed a petition for certiorari with the Court of Appeals, arguing that Maralit should not receive these benefits and contending that due process was afforded.
Court of Appeals' Ruling
The Court of Appeals reversed the NLRC’s resolution on May 31, 2004, asserting that the NLRC had committed grave abuse of discretion. The Court found Maralit was under an administrative investigation when she filed for early retirement, reiterating that due process had been satisfied.
Legal Issues Raised by Petitioner
In her subsequent petition, Maralit contested the NLRC’s affirmation of the Labor Arbiter’s decision, invoking claims about legal errors and alleged due process violations. She sought reinstatement based on the finality of the Labor Arbiter’s decision and argued that her effective retirement precluded any subsequent dismissal.
Court's Analysis
The Court held that Maralit’s claim regarding the NLRC's power was correctly founded on the Labor Code, which permits review of labor arbiters’ decisions. It emphasized that the NLRC’s actions did not constitute grave abuse of discretion simply by affirming a decision
...continue readingCase Syllabus (G.R. No. 163788)
The Case
- This case involves a petition for review on certiorari under Rule 45 of the Rules of Court, challenging the 31 May 2004 Decision of the Court of Appeals in CA-G.R. SP No. 72540.
- The Court of Appeals set aside the 27 August 2001 Resolution of the National Labor Relations Commission (NLRC) in NLRC NCR CA No. 027826-01.
- The NLRC had affirmed with modification the Labor Arbiter's 22 January 2001 Decision in Sub-RAB Case No. 05-09-00316-00.
The Facts
- Petitioner Ester B. Maralit worked for the Philippine National Bank (PNB) from 27 August 1968 to 31 December 1998, starting as a casual clerk and eventually becoming a branch manager.
- In February 1998, PNB introduced an early retirement plan through Board Resolution No. 1, which was formalized in General Circular No. 1-355/98 on 7 July 1998.
- This circular allowed personnel with pending administrative cases to apply for the Special Separation Incentive Plan (SSIP), but payment was conditional on the resolution of their cases.
- On 8 September 1998, PNB's Internal Audit Group (IAG) reported that Maralit violated bank policies, leading to the return of unfunded checks amounting to P54,950,000.
- The audit found that Maralit approved several transactions that contravened policies regarding drawings against uncollected deposits (DAUD).
Administrative Charges and Investigation
- Following the audit findings, PNB formally charged Maralit on 29 September 1998 with serious misconduct, gross violation of bank regulations, and conduct p