G.R. No. 159556 - Philippine Airlines Inc. vs. Court of Appeals

Factual findings made by quasi-judicial and administrative bodies are generally respected and accorded finality by courts when supported by substantial evidence.
Substantial evidence is defined as that level of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion.
Administrative bodies, such as the National Labor Relations Commission (NLRC), are not strictly bound by the technical rules of evidence that govern court proceedings.

Philippine Airlines, Inc. (PAL) filed a petition for review seeking to reverse the Court of Appeals' decision that found PAL liable for unlawfully terminating Alendry de Leon's employment.
The case arose from a complaint by Cesar Villanueva regarding the refund of his unused ticket, which led to an internal investigation revealing fraudulent activities involving several employees at PAL's Iloilo Airport Ticket Office.

The investigation uncovered that Villanueva's ticket was not properly processed, and another individual had fraudulently collected a refund for it.
Further inquiries revealed a pattern of fraudulent refunds involving over sixty passengers who confirmed they had taken their flights but had not requested refunds.
A Special Committee was formed to investigate the irregularities, leading to the identification of eight employees involved in the fraudulent scheme.

The eight employees, including respondent Alendry de Leon, were charged with fraud, falsification of company documents, and failure on the job.
They were given notices detailing the charges and were allowed to respond before a clarificatory hearing conducted by an Administrative Investigating Panel.
The panel found the employees guilty, leading to their dismissal from PAL.

The Labor Arbiter dismissed the complaints for illegal dismissal, finding substantial evidence supporting the just cause for termination.
Testimonies from passengers and the evidence presented established that the employees had engaged in fraudulent activities that deprived PAL of its rightful revenues.

The NLRC affirmed the Labor Arbiter's decision, emphasizing that conspiracy does not require a technical definition but can be established through substantial evidence of participation in the fraudulent scheme.

The Court of Appeals reversed the NLRC's decision regarding respondent De Leon, citing insufficient evidence to prove his involvement in the conspiracy.
The appellate court reasoned that De Leon's actions were part of his normal duties and did not necessarily indicate intent to defraud.