Case Summary (G.R. No. 153157)
Relevant Facts
On the evening of July 27, 1995, Jacqueline Tanedo and her family were at the Manila Station International to check in for flight No. 102. An employee, Joseph Arriola, approached Ms. Tanedo regarding the unpaid travel taxes. After receiving P2,000.00 from her, Arriola failed to issue a receipt, and although boarding passes were provided, they did not sit together on the flight. Consequently, Ms. Tanedo filed a complaint against both Arriola and Tongson after paying their travel taxes again on July 28, 1995.
Company Investigation and Findings
Following Tanedo's complaint, PAL conducted an investigation. Both Arriola and Tongson were charged under the company's Code of Discipline with corruption, extortion, and bribery. Despite being placed on preventive suspension, both employees initially failed to attend the hearings. Eventually, an inter-office memorandum resulted in their termination after evidence suggested their involvement in the alleged extortion.
Labor Arbiter's Decision
The Labor Arbiter’s decision, dated September 17, 1998, upheld the termination, finding Tongson guilty of serious misconduct for engaging in a conspiracy with Arriola to extort money from Ms. Tanedo. The Labor Arbiter emphasized that Tanedo's complaint substantiated the charges and established that both employees had acted in collusion, meriting dismissal under Article 282 of the Labor Code.
NLRC Ruling
Tongson appealed the Labor Arbiter’s decision to the National Labor Relations Commission (NLRC), which affirmed the Arbiter’s ruling on June 15, 1999. The NLRC found the termination justified based on the same evidence and reasoning.
Court of Appeals’ Decision
Upon further appeal, the Court of Appeals rendered a decision on August 24, 2001, reversing the NLRC's decision. The Court ruled that the evidence presented by PAL, largely based on the unverified complaint of Ms. Tanedo, did not fulfill the standard for substantial evidence. It deemed that her statements were hearsay, lacking the probative value needed to support the severity of the charges leading to dismissal.
Petitioner’s Arguments
PAL sought a review, arguing that the Appellate Court erred in its assessment of evidence and disregarded the unanimous findings of both the Labor Arbiter and the NLRC, which had independently corroborated the grounds for Tongson's termination based on established facts and procedural justice.
Supreme Court’s Rationale
The Supreme Court held that the nature of proceedings before the Labor Arbiter and NLRC is non-litigious, allowing for an evaluation based on position papers without the strict application of rules of evidence found in judicial courts. Th
...continue readingCase Syllabus (G.R. No. 153157)
Background of the Case
- The case arises from a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, which challenges the Decision dated August 24, 2001, and the Resolution dated April 18, 2002, issued by the Court of Appeals in CA-G.R. SP No. 54801.
- The events stem from an incident on July 27, 1995, involving Jacqueline Tanedo and her family at the Philippine Airlines (PAL) check-in counter, where they encountered employee Joseph Arriola regarding unpaid travel taxes.
Factual Background
- On the night of July 27, 1995, Jacqueline Tanedo and her family were directed by Arriola to counter No. 36 for travel document processing, where Ms. Tanedo submitted P2,000.00 for travel taxes but did not receive a receipt.
- Another PAL employee, Arthur B. Tongson, assisted in processing the travel documents and obtaining boarding passes but did not ensure the family was seated together as promised.
- Due to the lack of seating arrangements, the Tanedo family opted to take a later flight on July 28, 1995, and were charged P3,240.00 in travel taxes, which prompted Ms. Tanedo to file a complaint against Arriola and Tongson.
Petitioner’s Investigation
- PAL conducted an internal investigation, issuing a memorandum on February 6, 1996, charging both employees with corruption, extortion, and bribery.
- Tongson admitted to processing the travel documents but denied any wrongdoing regarding the alleged extortion.
- Despite being notified, both employees failed to attend clarificatory hearing