Case Summary (G.R. No. L-11262)
Facts of the Case
In September 1984, amid looming bankruptcy, NEA intervened in the management of PANELCO III. As part of its management overhaul, a performance audit of employees and an inspection of kilowatt-hour meters of consumers were conducted. During this audit, it was discovered that Luzon Perejas, a meter reader since December 21, 1981, had manipulated the electric meter readings of his colleagues and had installed a jumper wire on his own meter to unlawfully reduce his electricity consumption. Following this discovery, Perejas received memoranda from PANELCO requiring explanations for his actions, which he initially failed to provide.
Procedural History
Perejas submitted letters admitting to the charges on December 4 and December 5, 1984, and was subsequently terminated from his employment as of December 8, 1984. In January 1985, he filed a complaint against PANELCO for illegal dismissal and underpayment of wages before the NLRC. In response, PANELCO lodged a criminal complaint against him for theft of electric current.
Labor Arbiter's Decision
On December 10, 1986, Labor Arbiter Rimando ruled in favor of Perejas, ordering his reinstatement with back wages, but the award for back wages was later reduced by the NLRC to six months. PANELCO contended there was sufficient evidence for the dismissal, claiming the admissions of Perejas justified his termination.
Supreme Court Findings on Just Cause for Dismissal
The Supreme Court examined the justifications for dismissal and determined there was indeed just cause for termination based on Perejas's written admissions regarding his conduct. Although the Labor Arbiter had dismissed the significance of these admissions alongside other evidences, the Court highlighted that once an allegation is admitted, it does not need further proof. The Court noted that substantial evidence rather than proof beyond reasonable doubt is required in dismissal cases, emphasizing that Perejas's admissions constituted sufficient grounds for dismissal.
Procedural Due Process Issues
Despite validating the cause of dismissal, the Court found that PANELCO failed to comply with the procedural due process requirements stipulated in the Omnibus Rules implementing the Labor Code. Specifically, the Court addressed shortcomings in providing Perejas ample opportunity to defend himself before his dismissal. The timeframes given in the issued memoranda were insufficient for a proper defense, lacking the formality of a comprehensive investigation or a hearing.
Final Ruling and Indemnity
The Supreme Court reversed and set aside the NLRC’s decision while mandating
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Case Overview
- This case revolves around the termination of Luzon Perejas, an employee of the Pangasinan III Electric Cooperative, Inc. (PANELCO III), and the legality of his dismissal.
- The case was decided by the Supreme Court on November 13, 1992, under G.R. No. 89876.
- The primary issues include the validity of the dismissal based on the charges against Perejas, the procedural due process followed during his dismissal, and the subsequent appeal to the National Labor Relations Commission (NLRC).
Background Facts
- In September 1984, PANELCO was on the verge of bankruptcy, leading the National Electric Administration (NEA) to take over its management.
- As part of the management's measures, a performance audit of all employees and an inspection of electric meters were conducted.
- Luzon Perejas had been employed as a meter reader since December 21, 1981.
- During the audit, it was discovered that Perejas had manipulated meter readings and had a jumper wire attached to his own electric meter.
Charges Against Perejas
- Charge of Underreading: Perejas was found to have underread the electric consumptions of his co-employees from April to November 1984.
- Charge of Tampering: The presence of a jumper wire on his electric meter was discovered, leading to a memorandum requiring an explanation from him.
- Admission of Guilt: Perejas admitted to both charges in writing, expressing remorse and promising not to repeat the infractions.
Dismissal Process
- After receiving a series of memoranda requiring explanations for the charges, Perejas was dism