Case Summary (G.R. No. L-28298)
Key Dates and Procedural History
The incident in question occurred on April 2, 1992, when Eddie Damalerio was reported for allegedly being found with a guest's belongings in a suitcase. Following an administrative hearing on April 4, he was dismissed on April 13, 1992. Damalerio filed a complaint for illegal dismissal on May 19, 1992. The Labor Arbiter ruled in his favor on August 20, 1993. The National Labor Relations Commission (NLRC) later modified this decision, offering separation pay instead of reinstatement in November 1995. The petition for review was submitted to the Supreme Court on February 23, 1999.
Applicable Law
This case is examined under the provisions of the 1987 Philippine Constitution, particularly referencing labor standards concerning employee dismissal, due process, and rights related to employment benefits.
Summary of Events
On April 2, 1992, hotel guest Jamie Glaser observed Eddie Damalerio with his hand inside Glaser's suitcase. Although Damalerio claimed he was tidying up the room, Glaser reported the incident, leading to disciplinary action. An administrative hearing was held, where Damalerio denied wrongdoing, explaining he was attempting to organize scattered belongings. Subsequently, San Gabriel issued a memorandum confirming Damalerio’s termination for qualified theft based on the allegations.
Labor Arbiter's Decision
The Labor Arbiter, upon reviewing the evidence, deemed Damalerio’s dismissal illegal, citing insufficient grounds for termination and the necessity for employees to be treated fairly. He ordered Damalerio’s reinstatement and back wages from the date of his preventive suspension, alongside other benefits accrued during the suspension.
NLRC Review and Modification
Dissatisfied, the petitioner appealed to the NLRC, which modified the decision by allowing the option for separation pay instead of reinstatement. The NLRC found no conclusive evidence substantiating Damalerio's alleged qualified theft, indicating a lack of sufficient proof to justify the extreme measure of dismissal.
Issues Presented to the Supreme Court
The petitioner contested whether the NLRC committed grave abuse of discretion by failing to recognize claims of qualified theft supported by the incident in question. Another issue raised was whether the NLRC erred in its decision regarding Damalerio's entitlement to service charges during his suspension.
Supreme Court Ruling
The Supreme Court ruled that the petition lacked merit, emphasizing the petitioner’s failure to provide adequate evidence against Damalerio. The Court noted that unproven suspicions from an employer do not suffice to validate dismissal and reinforced the burden of proof resting with the employer to establish just cause for termination. Additionally, it ruled that Damalerio was entitled to his share of service charges given his
...continue readingCase Syllabus (G.R. No. L-28298)
Case Overview
- This case involves a special civil action for certiorari under Rule 65 of the Revised Rules of Court.
- The petitioner is Maranaw Hotels and Resort Corporation, the owner of Century Park Sheraton Manila.
- The respondents are the National Labor Relations Commission (NLRC) and Eddie Damalerio, a former employee.
Facts of the Case
- On April 2, 1992, Eddie Damalerio, a room attendant, was observed by a hotel guest, Jamie Glaser, with his hand inside Glaser's suitcase.
- Damalerio claimed he was tidying up the room but was reported by Glaser, who had previously experienced Damalerio asking for souvenirs and giveaways.
- A Disciplinary Action Notice was issued to Damalerio on April 3, 1992, followed by an administrative hearing involving several hotel staff.
- During the hearing, Damalerio denied the theft accusation and explained he was merely cleaning the room and had found the guest's belongings scattered.
- On April 13, 1992, Damalerio received a memorandum stating he was found guilty of qualified theft and was subsequently terminated from his employment.
Proceedings Before the Labor Arbiter
- On May 19, 1992, Damalerio filed a complaint for