Case Summary (G.R. No. 214915)
Overview of Proceedings
This petition for review on certiorari sought to reverse the decisions of the Court of Appeals, which had nullified the decision of the National Labor Relations Commission (NLRC) that found Navaja’s dismissal from Oikonomos valid. The pivotal incident occurred on August 25, 2010, when Navaja allegedly found a white Nike jacket in Room 1202 while performing his duties.
Employee’s Position
Navaja contended that upon finding the jacket, he placed it at the back of his pants to free his hands for carrying a wine crate. While he reported for his following shift, he initially did not disclose the jacket's finding, later turning it over to the housekeeping office for lost and found. After an administrative hearing, he was dismissed for theft and dishonesty.
Employer’s Position
In contrast, Oikonomos maintained that Navaja had a history of infractions and that the surveillance footage illustrated suspicious behavior. It asserted that he concealed the jacket and failed to report his finding through proper channels, violating company protocols regarding lost and found items.
Labor Arbiter Ruling
The Labor Arbiter ruled in favor of Oikonomos, asserting that Navaja’s actions constituted theft and dishonesty, finding him guilty based on the CCTV evidence and his failure to report. The Arbiter awarded Navaja a minimal payment for his 13th month pay and service incentive leave.
NLRC Ruling
The NLRC upheld the Labor Arbiter’s ruling, affirming that Navaja’s dismissal was justified due to his violation of company policies and failure to report the jacket promptly.
CA Ruling
The Court of Appeals, however, overturned the prior decisions, concluding that Navaja did not exhibit intent to steal as he had not taken the jacket off the hotel premises. It held that Oikonomos had not sufficiently proven dismissal was warranted, leading to a decree of illegal dismissal.
Issues Raised
Two primary issues emerged from the appeal: whether a question of fact could be entertained in a review on certiorari and whether Oikonomos had proven with substantial evidence that Navaja's dismissal was justified by serious misconduct.
Court's Ruling
The Supreme Court recognized merit in Oikonomos’ petition, reiterating that generally, questions of fact are not within the purview of the Court unless specific exceptions apply. Here, the conflicting factual determinations between the CA, NLRC, and Labor Arbiter warranted a thorough examination.
Finding of Serious Misconduct
The Court concluded that Oikonomos established with substantial evidence that Navaja committed serious misconduct. The evidence indicated that he intentionally concealed the jacket and failed multiple opportunities to report
...continue readingCase Syllabus (G.R. No. 214915)
Background of the Case
- This case involves a petition for review on certiorari by Oikonomos Int'l Resources Corporation against Antonio Y. Navaja, Jr., challenging the decisions of the Court of Appeals which overturned earlier rulings regarding Navaja's dismissal.
- The petition seeks to reverse the May 29, 2013 Decision and the September 4, 2014 Resolution of the Court of Appeals, which nullified the December 29, 2011 Decision of the National Labor Relations Commission (NLRC) that upheld Navaja's dismissal as valid.
Factual Summary
- Employment Details: Navaja was hired as a room attendant by Oikonomos (formerly Hilton Cebu Resort and Spa) on December 27, 2004, and worked the graveyard shift.
- Incident Description: On August 25, 2010, Navaja found a white Nike jacket in Room 1202 while performing his duties. He placed the jacket at the back of his pants to carry a wine crate, later putting it in a plastic bag to bring to the Lost and Found Section.
- Subsequent Actions: Navaja forgot about the jacket after completing his duties. On August 26, 2010, he was questioned by hotel security regarding the jacket but did not initially report it until later that morning, leading to his preventive suspension on suspicion of theft.
Employer's Position
- Oikonomos argued that Navaja had a history of infractions, including lost items and inefficiency, and claimed he acted suspiciously as captured by CCTV footage.
- The company asserted that Navaja intentionally concealed the jacket and failed to follow pro