Case Summary (G.R. No. 187731)
Facts of the Case
The factual background centers on the termination of employment of the three respondents, who were Traffic Operators at PLDT's Davao Exchange. Totesora and Marcos were dismissed for allegedly making free long-distance calls, while Macabenta's probationary employment was terminated for failure to meet minimum employment standards. Totesora and Marcos stated that their actions did not constitute a full violation, while Macabenta argued that her employment status entitled her to regularization.
Voluntary Arbitration and Initial Ruling
The disputes were submitted for voluntary arbitration, with Arbitrator Montemayor ultimately ruling that while Totesora and Marcos had indeed violated company policies, the sanction of dismissal was excessively harsh for a first offense; thus, he recommended their reassignment instead. In contrast, he noted the unusual delay in Macabenta’s probationary classification, concluding that she was entitled to reinstatement as a regular employee.
Petitioner's Claims of Error
PLDT's petition for certiorari challenged Montemayor’s findings, alleging grave abuse of discretion in ordering the reinstatement of Totesora and Marcos despite their violations, as well as in classifying Macabenta as a regular employee. The company asserted that the acts committed by Totesora and Marcos warranted dismissal and maintained that the arbiter did not have the authority to contravene the established company policies.
Judicial Review of Arbitration Findings
The Supreme Court highlighted the principle that findings by voluntary arbitrators, operating in a quasi-judicial capacity, should generally be respected. The Court clarified that while such decisions uphold a degree of finality, they remain subject to judicial review, particularly in instances of jurisdictional issues or abuse of discretion.
Conclusion on Dismissal of Totesora and Marcos
The Court found that Montemayor had gravely abused his discretion by reinstating Totesora and Marcos, whose actions were deemed detrimental to the employer-employee trust relationship. The acts of dishonesty they committed were substantial enough to justify dismissal according to company rules, despite the argument that outright termination for a first offense might usually be considered excessive.
Macabenta's Employment Status
Conversely, the Court ack
...continue readingCase Syllabus (G.R. No. 187731)
Case Overview
- This case revolves around a petition for certiorari filed by the Philippine Long Distance Telephone Company (PLDT) against Voluntary Arbitrator Alberto Montemayor and several private respondents, namely Ma. Emma J. Totesora, Miricar A. Marcos, and Maria Lourdes U. Macabenta.
- The petition challenges the resolution dated February 14, 1989, concerning the dismissal of the private respondents and the subsequent denial of the motion for reconsideration on May 12, 1989.
Factual Background
- The private respondents were Traffic Operators at PLDT's Davao Exchange.
- Ma. Emma J. Totesora and Miricar A. Marcos were regular employees dismissed for allegedly facilitating free long-distance calls, while Maria Lourdes U. Macabenta, who was on probationary status, was terminated for failing to meet minimum employment requirements.
- Totesora explained her actions by stating that she allowed callers to talk longer without timing the calls, while Marcos admitted to placing a free call to her brother.
Dismissal and Arbitration
- PLDT terminated Totesora and Marcos for their actions, deeming it a violation of company regulations.
- Macabenta's employment was claimed to have been probationary, but she argued that she had worked continuously from April 1985 to August 1986 and should have been regularized.
- Both parties agreed to submit their disputes to voluntary arbitration, resulting in Arbitrator Montemayor's resolution, which found violations