Case Summary (G.R. No. 203160)
Antecedent Facts
Llorente was employed by Metro Psychiatry, Inc. in November 2007. His employment came under scrutiny after he was issued a memorandum on June 22, 2016, requiring an explanation for his refusal to perform assigned tasks. Following a subsequent memorandum regarding allegations of false reporting of abuse towards a patient, Llorente was placed on preventive suspension. He disputed the claims in his explanation, arguing that the alleged failure to perform duties was untrue, emphasizing that cleaning was not part of his responsibilities as a nursing attendant. His dismissal was officially communicated to him on September 5, 2016, prompting him to file a complaint asserting constructive dismissal due to alleged harassment and discriminatory practices by the management.
Ruling of the Labor Arbiter
The Labor Arbiter's Decision on April 28, 2017, dismissed Llorente's complaint for lack of merit. The Arbiter established that Llorente had not resigned but had been terminated for valid reasons, including substantial evidence of misconduct, particularly for maliciously reporting false information concerning the alleged maltreatment of a patient. The Arbiter also determined that Llorente's claims of harassment were unsustained, noting that tasks like cleaning were routinely assigned among staff, including Llorente.
Ruling of the NLRC
The NLRC, in its August 23, 2017 ruling, upheld the Labor Arbiter's dismissal of Llorente's complaint regarding wrongful termination but modified the decision to include entitlement to various employee benefits, such as salary differentials and holiday pay. This modification recognized Llorente's contributions prior to dismissal while affirming the legality of his termination based on substantial evidence of misconduct.
Ruling of the Court of Appeals
The Court of Appeals, in a decision dated October 16, 2018, reversed the findings of both the NLRC and the Labor Arbiter, concluding that Metro Psychiatry failed to substantiate the grounds for termination. The CA based its decision on perceived inadequacies in the evidence against Llorente, favoring his claims of harsh treatment and suggesting that the dismissal was not proportionate to the alleged infractions.
Issue
The principal issue presented before the Supreme Court was whether the Court of Appeals erred in concluding that Llorente was illegally dismissed, thereby reversing the judgments rendered previously by the labor tribunals.
Ruling of the Supreme Court
The Supreme Court granted the petition for review and reversed the decision of the Court of Appeals, reinstating the NLRC’s ruling. The Court highlighted that while the CA's review is typically confined to questions of law, it stepped into areas of factual determination that contradicted the Labor Arbiter’s and NLRC’s findings. The Court underscored that the standard for validating termination was "substantial evidence," which had been sufficiently met through corrobo
...continue readingCase Syllabus (G.R. No. 203160)
Background of the Case
- The case originates from a Petition for Review on Certiorari filed by Metro Psychiatry, Inc. (MPI) against Bernie Llorente.
- The petition challenges the Decision dated October 16, 2018, and Resolution dated February 12, 2019, of the Court of Appeals (CA) in CA-G.R. SP No. 153723.
- The CA reversed the earlier decisions of the National Labor Relations Commission (NLRC) and the Labor Arbiter (LA), which had upheld Llorente's dismissal.
Antecedent Facts
- Bernie Llorente was employed as a nursing attendant by MPI, a corporation providing psychiatric care, starting in November 2007.
- On June 22, 2016, Llorente received a Memorandum asking for an explanation regarding his refusal to perform assigned tasks.
- On July 9, 2016, another Memorandum accused him of falsely reporting maltreatment of a patient and failing to follow instructions.
- The complaint arose after an incident involving a patient, David Warren Tan, where Llorente allegedly communicated false information about Tan's treatment to his mother.
- Evidence included closed-circuit television (CCTV) footage showing Llorente acting suspiciously, which led to his preventive suspension.
Procedural History
- Llorente denied the allegations, asserting he was merely performing his duties and that he was subjected to harassment.
- He was ultimately terminated on September 5, 2016, for loss of trust and confidence, as well as willful disobed