Title
Philippine Long Distance Telephone Co. vs. Tolentino
Case
G.R. No. 143171
Decision Date
Sep 21, 2004
A 23-year PLDT manager, accused of involvement in a land acquisition anomaly, was illegally dismissed; courts ruled insufficient evidence for loss of trust, ordering reinstatement with backwages.

Case Summary (G.R. No. 208844)

Employment Background

Tolentino began his tenure at PLDT in 1972 as an installer/helper and was promoted to a managerial role. His responsibilities included evaluating and recommending documents for provincial acquisitions. In 1995, a controversy arose when a supervisor under Tolentino, Jonathan de Rivera, created an internal arrangement concerning a land acquisition that was to be evaluated by Tolentino's division.

Internal Arrangement and Dismissal

The internal arrangement allegedly involved a scheme where only a portion of the purchase price for a parcel of land would be properly disbursed, with undisclosed terms laid out in an affidavit by Quirino Donato, the attorney-in-fact for the landowner. Following the revelation of this arrangement, de Rivera was dismissed, which led him to submit a statement implicating Tolentino. In response to these allegations, Tolentino denied involvement and pointed out the limitations of his authority regarding real estate transactions.

Termination Process

On October 27, 1995, PLDT issued a notice of dismissal to Tolentino, alongside a handwritten note from Sacdalan offering him the option to resign. The formal dismissal was finalized on December 5, 1995, without a prior formal hearing for Tolentino, prompting him to file a complaint for illegal dismissal and related claims in January 1996.

Labor Arbiter's Decision

The labor arbiter ruled in favor of Tolentino, establishing that PLDT failed to substantiate the claims against him and declared the termination illegal. He ordered Tolentino’s reinstatement, along with substantial backwages and damages.

NLRC's Reversal

Upon appeal, the National Labor Relations Commission (NLRC) reversed the labor arbiter's ruling, arguing that Tolentino's status as a managerial employee justified the dismissal based on loss of trust and confidence. This decision was contested, leading to a certiorari petition brought by Tolentino to the Court of Appeals.

Court of Appeals Ruling

The Court of Appeals reinstated the labor arbiter's decision, concluding that PLDT's grounds for dismissal lacked substantial evidence required to legally uphold the action. The court emphasized the company’s failure to demonstrate that Tolentino’s actions warranted loss of trust, asserting that mere suspicion could not justify dismissal.

Supreme Court's Analysis

The Supreme Court maintained that while managerial employees could be dismissed under loss of trust, the justifications for Tolentino’s termination did not meet the necessary standards. It reiterated that security of tenure, even for managerial employees, must be respected and that dismissals must be based on clearly established facts rather than speculation

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