Case Summary (G.R. No. 96525)
Background Facts
Prosserpina Presidente began her employment with Mercury Drug Corporation as a Pharmacy Assistant on November 17, 1980, and was later transferred to the Los Banos Branch on May 10, 1983. The Los Banos branch struggled with sales, prompting the then-Manager, Willie Hidalgo, to implement practices that accommodated customer requests for receipts reflecting purchases made at other branches based on presentation of cash register tapes. This practice continued even after Hidalgo left the branch.
Incident of Alleged Falsification
In December 1986, Presidente issued a receipt based on a cash register tape for a regular customer, Mr. Genaro Revilleza. On February 24, 1987, she again accommodated a request from Revilleza to add items from a previous purchase made at another branch to an existing invoice, which was validated by the cashier, Remedios de Luna. Following these transactions, Mr. Sammy Carpio became the new manager and instructed employees to report suspicious activities.
Complaint and Dismissal
On March 23, 1987, Carpio summoned Presidente to the main office where she was confronted about the February 24 incident. Under pressure from management, she was induced to resign, feeling coerced and without voluntary consent. After doing so, she filed a complaint for illegal dismissal on April 23, 1987, seeking back pay, moral damages, and attorney's fees.
Labor Arbiter Ruling
The Labor Arbiter ruled on February 27, 1989, that Presidente was illegally dismissed and ordered her reinstatement with back wages, period salary, and attorney fees, dismissing other claims for lack of merit.
NLRC Resolution
The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision on November 29, 1990, rejecting Mercury Drug's appeal on grounds of lack of merit.
Supreme Court Analysis
Mercury Drug contended that the NLRC exhibited grave abuse of discretion by disregarding the evidence on falsification claims and failing to recognize company policies prohibiting such actions. However, the Supreme Court found that:
- Although Presidente had added items to the receipt, such actions did not constitute falsification as defined under Article 172 of the Revised Penal Code, since no evidence of prejudice or intent to harm was demonstrated.
- The scheme originated from prior management and was cond
Case Syllabus (G.R. No. 96525)
Case Background
- The case involves a petition for review on certiorari filed by Mercury Drug Corporation against the National Labor Relations Commission (NLRC) regarding the illegal dismissal of Prosserpina Presidente.
- The NLRC's resolution dated November 29, 1990, upheld the Labor Arbiter's decision from February 27, 1989, which found that Presidente was illegally dismissed and ordered her reinstatement with back wages and attorney's fees.
- The petitioner contended that the private respondent's actions constituted falsification, providing grounds for her dismissal.
Employment and Company Practices
- Prosserpina Presidente began her employment with Mercury Drug on November 17, 1980, as a Pharmacy Assistant, later transferring to the Los Banos Branch on May 10, 1983.
- To address low sales, former manager Willie Hidalgo implemented a scheme allowing the issuance of receipts reflecting purchases made at other branches based on cash register tapes.
- This practice was continued even after Hidalgo's departure, aimed at assisting customers with refunds and boosting goodwill for the company.
Incident Leading to Dismissal
- On February 24, 1987, a regular customer, Genaro Revilleza, requested that Presidente issue a receipt for his previous purchase based on a cash register tape.
- The receipt was validated by the branch cashier, Remedios de Luna.
- A few days later, another request was made to add items purchased from a different branch to a cash invoice,