Case Summary (G.R. No. 172589)
Applicable Law
The relevant legal framework includes the 1987 Philippine Constitution, the Labor Code of the Philippines, Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002), and the Department Order No. 53-03 issued by the Department of Labor and Employment (DOLE).
Facts of the Case
Nacague was employed by Sulpicio Lines on June 15, 1995, and served as the "hepe de viaje" on board its vessel. In January 2003, the company received an anonymous tip about drug use aboard the ship. A formal investigation commenced following a report from a crew member about drug paraphernalia and threats made against him by Nacague and his supervisor. On February 18, 2003, a random drug test conducted through S.M. Lazo Medical Clinic indicated that Nacague tested positive for methamphetamine hydrochloride.
After undergoing a separate voluntary drug test at Chong Hua Hospital, which returned a negative result, Sulpicio Lines terminated Nacague's employment on March 7, 2003, citing grave misconduct and loss of trust. Nacague subsequently filed a complaint for illegal dismissal with the labor authorities.
Labor Arbiter's Decision
On November 12, 2003, the Labor Arbiter ruled in favor of Nacague, declaring his dismissal illegal. The Labor Arbiter found the drug test from S.M. Lazo Clinic questionable because it was not accredited by the Dangerous Drugs Board, whereas the test from Chong Hua Hospital was deemed credible. The Labor Arbiter ordered Sulpicio Lines to pay Nacague separation pay and back wages but did not order reinstatement due to strained relationships.
NLRC and Court of Appeals Decisions
Dissatisfied with the Labor Arbiter's ruling, Sulpicio Lines appealed to the National Labor Relations Commission (NLRC), which, on March 21, 2005, reversed the Labor Arbiter's decision, asserting that Nacague's employment termination was valid due to his positive drug test constituting serious misconduct and loss of trust. The NLRC upheld the presumption of S.M. Lazo Clinic's accreditation and determined that it was Nacague's burden to prove otherwise.
Nacague’s motion for reconsideration was denied on May 31, 2005, prompting him to file a petition for certiorari with the Court of Appeals. In its January 23, 2006 decision, the Court upheld the NLRC's ruling, confirming that Sulpicio Lines met both the procedural and substantive requirements of the law regarding Nacague's dismissal.
Supreme Court's Ruling
The Supreme Court found merit in Nacague's petition and highlighted that Sulpicio Lines failed to establish the credibility of the S.M. Lazo Clinic drug test, pointing out that it did not provide proof of accreditation as mandated by Republic Act No. 9165. The Court emphasized that the law prescribed the requirement for both a screening test and a confirmatory test; in this case, only a screening test was condu
...continue readingCase Syllabus (G.R. No. 172589)
The Case
- This case is a petition for review of the Decision dated January 23, 2006, and the Resolution dated April 19, 2006, by the Court of Appeals in CA-G.R. CEB SP No. 01065.
- The Court of Appeals dismissed the petition for certiorari filed by Jeffrey Nacague (petitioner) and affirmed the National Labor Relations Commission (NLRC) decision dated March 21, 2005, and the resolution dated May 31, 2005.
- The NLRC had dismissed Nacague's complaint regarding illegal suspension and dismissal from employment.
The Facts
- On June 15, 1995, Nacague was hired by Sulpicio Lines, Inc. as "hepe de viaje" (representative) on the M/V Princess of the World.
- On January 25, 2003, Sulpicio Lines received an anonymous letter alleging drug use on board the vessel.
- On February 14, 2003, Ceasar T. Chico, a ship housekeeper, reported finding drug paraphernalia and threats made against him by Nacague and Chief Mate Reynaldo Doroon.
- Following the report, Sulpicio Lines notified Nacague of an investigation concerning drug use and threats.
- A random drug test conducted on February 18, 2003, at S.M. Lazo Medical Clinic indicated that Nacague tested positive for methamphetamine (shabu).
- Nacague denied the drug use during a formal investigation on February 20, 2003.
- He voluntarily underwent another drug test at Chong Hua Hospital on February 23, 2003, which returned a negative result.
- Despite this, Nacague was terminated from his position on March 7, 2003, based on the positive drug test result from S.M. Lazo Clinic.
The Labor Arbiter's Decision
- Nacague filed a complaint f