Case Summary (G.R. No. L-1721)
Factual Background
Romeo F. Bolso was employed as an Installer/Repairman II by PLDT since February 1982 until his dismissal on July 20, 1997. The controversy began when Ismael Salazar, a subscriber, alleged that he had paid Bolso, whom he identified as "Boy Negro," for the illegal installation of an extension line. This claim led to an internal investigation where Salazar positively identified Bolso as the installer. However, Salazar later executed a recantation letter, claiming he did not know Bolso personally and was incorrectly influenced during the identification.
Findings of the Labor Arbiter
The Labor Arbiter initially dismissed Bolso's complaint for illegal dismissal, stating that the evidence presented by Bolso was speculative and lacked merit, primarily relying on Salazar's retraction. Despite acknowledging the absence of direct evidence of Bolso’s personal wrongdoing, the decision underscored the serious misconduct associated with the infraction.
NLRC Ruling
In an appeal, the NLRC ruled in favor of Bolso, stating that PLDT failed to sufficiently prove Bolso's culpability. The NLRC noted that Salazar’s recantation significantly impacted the determination of Bolso’s innocence. Furthermore, the NLRC recognized that Bolso's dismissal violated his right to due process, as his defense was inadequately considered in the investigative process.
Court of Appeals Decision
The Court of Appeals sustained the NLRC ruling, highlighting that Salazar’s recantation created reasonable doubt regarding Bolso's culpability. The court also emphasized the lack of evidence against Bolso, concluding that dismissal was an excessive penalty, especially given Bolso's years of service and the first-time nature of the alleged infraction. It was determined that Bolso had not been afforded a fair opportunity to present a defense during the investigation.
Supreme Court Ruling
The Supreme Court ultimately sided with the Court of Appeals, reaffirming the NLRC’s decision. It articulated the standards for just cause in termination under the Labor Code, stating that serious misconduct must be substantiated by substantial evidence. The court scrutinized the dynamics surrounding Salazar’s recantation, asserting that his initial claims regarding Bolso’s involvement in the installation of an illegal line remained unrefuted, as he did not retract his assertion of having paid Bolso.
Just Cause and Due Process
The Court acknowledged that despite the recognition of Bolso’s extended service and the implications of Salazar's potential inaccuracies, these factors could not negate the misconduc
...continue readingCase Syllabus (G.R. No. L-1721)
Introduction
- This case involves a petition for review filed by the Philippine Long Distance Telephone Company (PLDT) against the ruling of the Court of Appeals which affirmed the decision of the National Labor Relations Commission (NLRC) declaring the dismissal of Romeo F. Bolso as illegal.
Background of the Case
- Bolso served as an Installer/Repairman II for PLDT from February 1982 until his dismissal on July 20, 1997.
- The case revolves around an incident where Salazar, a PLDT subscriber, accused Bolso of illegally installing an extension line after purchasing a telephone line from another subscriber.
Events Leading to Dismissal
- On February 5, 1996, Salazar purchased a telephone line from Mabunga and later claimed that Bolso, who he identified as "Boy Negro," installed an unauthorized extension of that line.
- Salazar filed complaints with PLDT regarding the unauthorized use of his telephone line by Mabunga.
- PLDT launched an investigation, during which Salazar positively identified Bolso as the installer of the illegal extension.
Investigation and Allegations
- Salazar provided a Sinumpaang Salaysay narrating the circumstances of the illegal installation.
- During an investigation on July 26, 1996, Salazar reaffirmed his identification of Bolso as the inst