Case Summary (G.R. No. 120474)
Factual Background
Aniceto W. Naguit, Jr. served as an Administrative Officer for MERALCO at its Sta. Cruz, Laguna Branch from August 11, 1959, until his dismissal on June 13, 1991. His dismissal followed allegations of falsifying a time card and inducing a co-worker to claim payment for unrendered work. The company claimed Naguit was found guilty following an investigation and administrative hearings conducted by MERALCO.
Overtime Work and Dismissal
On June 6, 1987, Naguit informed his supervisor, Sofronio Ortega, Jr., about his intention to work overtime and afterwards attend a family wedding in Pagbilao, Quezon. The timekeeper mistakenly recorded that Naguit worked from 8:00 a.m. to 5:00 p.m. on June 6 and 7, 1987. Although he corrected this oversight by erasing the June 7 entry, he received payment for his claimed overtime work on June 6. An investigation into Naguit’s actions commenced over two years later, culminating in his dismissal for alleged misconduct.
Administrative Investigation Findings
MERALCO’s Special Presidential Committee, following administrative hearings, found Naguit guilty of violations under the company's Employee Discipline Code, specifically for falsifying time records and encouraging another employee (Fidel Cabuhat) to perform a deceitful act. The company asserted that Naguit’s actions constituted serious misconduct and ultimately led to the termination of his employment.
Labor Arbiter's Ruling
In response to his dismissal, Naguit filed a complaint for illegal dismissal with the NLRC. The Labor Arbiter ruled in his favor on April 7, 1993, ordering MERALCO to reinstate him with back wages for two years, claiming that his actions were consistent with company policy regarding field personnel and did not constitute misconduct.
NLRC’s Reversal
MERALCO appealed the Labor Arbiter's ruling, arguing that the findings were contrary to law and disregarded evidence supporting their justification for Naguit's termination. On November 28, 1994, the NLRC reversed the Labor Arbiter’s decision, dismissing Naguit’s complaint on the basis that the evidence clearly supported the allegations of misconduct.
Supreme Court Review
Naguit subsequently filed a petition for certiorari before the Supreme Court, alleging that the NLRC's conclusions were unsupported by evidence and that the testimonies from key witnesses were improperly weighted. The Court found that Naguit had valid reasons to believe he was conforming to company policy regarding field assignments, and that the evidence against him, especially affidavits from Cabuhat, was inadmissible due to the lack of cross-examination opportunities.
Court’s Decision
The Supreme Court ruled in favor of Naguit, stating that the charge of falsification did not stand as he had worked according to company policies which allowed fl
...continue readingCase Syllabus (G.R. No. 120474)
Case Overview
- The case involves a petition for certiorari filed by Aniceto W. Naguit, Jr. seeking to annul the November 28, 1994 Decision and March 28, 1995 Resolution of the National Labor Relations Commission (NLRC).
- The petitioner, Naguit, was employed by Manila Electric Company (MERALCO) since August 11, 1959 and was dismissed on June 13, 1991 after 32 years of service.
Background of the Case
- Naguit served as the Administrative Officer at MERALCO's Sta. Cruz, Laguna Branch at the time of his dismissal.
- On June 5, 1987, he informed his supervisor, Sofronio Ortega, Jr., of his planned overtime work on June 6, 1987, followed by a trip to Pagbilao, Quezon for a family wedding.
- He arrived at the Sta. Cruz office at 7:50 a.m. on June 6, 1987, proceeded with field assignments until noon, and then traveled to Pagbilao.
Events Leading to Dismissal
- On June 8, 1987, an Overtime Notice was prepared showing Naguit worked from 8:00 a.m. to 5:00 p.m. on June 6, 1987, which he later corrected.
- More than two years later, MERALCO's Legal and Investigation Staff informed Naguit of allegations involving falsification of time cards and unauthorized absence.
- Formal administrative hearings were conducted on February 27, 1990, and July 16, 1990, where Naguit waived his right to counsel and denied the charges against him.
Evidence and Findings
- The evidence presented against Naguit primarily consisted of sworn statements from co-employee Fidel Cabuhat and others, alleging that Naguit induced Cabuhat to falsely claim reimbursement for expenses not incurred during work.
- On April 22, 1991, t