Case Summary (G.R. No. 180219)
Background of the Case
Eduardo Pangan began his employment with PLDT in 1970. His job responsibilities included the repair and maintenance of telephone lines and handling various cable facilities. In early 1977, an audit revealed that Pangan, along with three other employees, had engaged in the theft of company properties. Pangan returned several unserviceable items while admitting to having sold some new tools to cover his personal financial burdens, specifically medical expenses related to a goiter operation. His actions led PLDT to file for clearance to terminate his employment based on the findings of theft and misappropriation.
Labor Arbiter Decision
Following Pangan's dismissal, he filed a complaint against PLDT with the Department of Labor, which was subsequently dismissed by the Labor Arbiter for lack of merit. The Arbiter determined that the evidence presented warranted dismissal, as it constituted a serious act of misconduct.
NLRC Decision
On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter's ruling, ordering Pangan's reinstatement without backwages. The NLRC cited mitigating circumstances, including Pangan's commendable act during a fire incident at PLDT's Pasay Central Office and the financial strain he faced due to his medical needs. The NLRC believed that while Pangan's actions were wrong, they were not severe enough to warrant the "supreme industrial penalty of dismissal," particularly given the good faith actions of PLDT in addressing the situation.
Supreme Court Ruling
PLDT subsequently sought certiorari from the Supreme Court, arguing that the NLRC had committed grave abuse of discretion by ordering Pangan’s reinstatement despite clear misconduct. In evaluating the situation, the Supreme Court found that PLDT had valid grounds for terminating Pangan's employment due to the established theft of company property, which falls under just causes for dismissal as per Article 282 of the Labor Code.
Legal Precedents and Arguments
The Court referenced previous cases, including Firestone Tire and Rubber Co. of the Phils. v. Lariosa, where the dismissal of an employe
...continue readingCase Syllabus (G.R. No. 180219)
Case Background
- The case involves the Philippine Long Distance Telephone Company (PLDT) as the petitioner and Eduardo Pangan as the private respondent, alongside the National Labor Relations Commission (NLRC).
- Pangan was employed by PLDT as a lineman-helper starting in 1970 and held the position of lineman II at the time of his dismissal.
- His job responsibilities included repairing telephone lines, canvassing affected numbers, and handling cable facilities.
Incident Leading to Dismissal
- In early 1977, Pangan was implicated in the pilferage of company property along with three other employees.
- An audit revealed discrepancies in Pangan’s tool accountability; he returned worthless materials valued at P2,402.00 to offset prior requisitions.
- Pangan admitted to selling two new leather belts and one handset, totaling P1,609.00, citing financial need due to hospital expenses from a goiter operation.
Company Actions and Legal Proceedings
- PLDT filed for clearance to terminate Pangan on May 31, 1977, citing theft and misappropriation.
- The Department of Labor granted this application on September 27, 1977.
- Pangan opposed the t