Case Summary (G.R. No. 200102)
Background of the Case
Lettie Corpuz was employed at the Manila International Traffic Division (MITD) within PLDT. Following a strike by rank-and-file employees in December 1987, her supervisors temporarily took on the duties of the traffic operators. During this time, two supervisors handled incoming calls from an anomalous telephone number (98-68-16) that had been disconnected. Investigating the calls made through this number revealed an extensive number of international calls had been processed, with a significant portion being managed by Corpuz.
Findings and Allegations Leading to Dismissal
Investigation by PLDT's Quality Control Inspection Department established that Corpuz handled 34 calls after the number's disconnection without adhering to the requisite verification processes. On July 26, 1988, Corpuz was asked to explain her actions but instead requested a formal investigation, which did not occur as she had intended. The Legal Department recommended her dismissal based on serious misconduct and loss of trust. Consequently, she was terminated effective June 17, 1989.
Legal Proceedings and Labor Arbiter's Ruling
Corpuz subsequently filed a complaint for illegal dismissal against PLDT. Labor Arbiter Jose G. De Vera delivered a ruling in favor of Corpuz on February 28, 1991, ordering her reinstatement with back wages amounting to P103,381.50 and attorney’s fees. This ruling was upheld in full by the National Labor Relations Commission (NLRC) on November 16, 1992, which also denied PLDT’s motion for reconsideration on August 20, 1993.
Review of Dismissal Justifications
The Supreme Court reviewed the case under the premise that dismissals must be supported by substantial evidence rather than mere speculation. The Court emphasized that the employer's prerogative to terminate an employee is subject to state regulations protecting labor rights. It found no substantial evidence that Corpuz acted fraudulently or that her handling of the calls constituted defrauding the company. Both the evidence and testimonies indicated that continuous calls from disconnected numbers could occur, especially when considering testimony from other operators regarding similar phenomena.
Due Process and Labor Rights
The ruling underscored the importance of due process in employment dismissal cases, particularly that the employee must be granted a fair opportunity to explain their side. The employer
...continue readingCase Syllabus (G.R. No. 200102)
Case Overview
- This case involves a petition for certiorari filed by the Philippine Long Distance Telephone Company (PLDT) against the National Labor Relations Commission (NLRC) and Lettie P. Corpuz concerning an illegal dismissal complaint.
- The background of the case includes the employment of Lettie Corpuz as a traffic operator at PLDT for over ten years, followed by her dismissal on June 17, 1989.
- The core issue revolves around allegations of serious misconduct and breach of trust related to the handling of calls from a supposedly disconnected telephone number.
Background Facts
- Lettie Corpuz worked at PLDT from September 19, 1978, until her dismissal.
- During a strike by rank-and-file employees in December 1987, supervisors took over the duties of telephone operators.
- Two supervisors received simultaneous requests for calls from the same number, which was later found to be disconnected.
- An investigation revealed that there were 439 overseas calls made through this number during a specific timeframe, with Corpuz handling a significant portion of those calls.
Investigation and Findings
- The Quality Control Inspection Department (QCID) established that the subject telephone number was disconnected on June 10, 1987, and permanently on September 24