Case Summary (G.R. No. 190147)
Relevant Facts and Company Rules
Ramoran submitted overtime (OT) authorization slips for alleged overtime work covering several dates in November and December 1993, which were later questioned for authenticity. Jardine's policies required that an OT authorization slip must pertain to one date and be submitted timely. However, on December 18, 1993, HRD employees noticed irregularities in Ramoran's OT slips, including that the slips had been improperly backdated and tampered with, which violated company rules.
Administrative Investigation and Termination
An administrative investigation into the irregularities commenced on February 1, 1994, with various parties present, including union representatives. Ramoran admitted to intending to catch up on work after serving a previous suspension but denied wrongdoing. Nevertheless, the investigation concluded that she had committed falsification, leading to her termination on April 4, 1994, under Rule 32 of the Company Rules, which penalized such offenses with dismissal.
Legal Proceedings Initiated by the Union
The Jardine union subsequently filed a Notice of Strike, framing Ramoran's termination as illegal. An arbitration process followed, ultimately involving both the union and the company to resolve the legality of her dismissal, with the union asserting violations of due process and wrongful termination.
Findings of the Panel of Voluntary Arbitrators
The Panel of Voluntary Arbitrators, after reviewing the evidence presented, upheld Ramoran's termination, concluding that she had engaged in misconduct through falsification of her overtime records. The ruling emphasized that dismissal did not require proof beyond a reasonable doubt but only substantial evidence that justified such action.
Criminal Proceedings and Subsequent Developments
Criminal cases were filed against Ramoran for falsification, resulting in her conviction in one case and acquittal in another. Following her acquittal, Ramoran attempted to overturn the arbitration decision, asserting her belief that the acquittal should affect her termination.
Court of Appeals Ruling
The Court of Appeals denied Ramoran's petition for certiorari, emphasizing that the findings by the Panel of Voluntary Arbitrators should be respected and that her dismissal was justified based on substantial evidence. The ap
...continue readingCase Syllabus (G.R. No. 190147)
Case Overview
- The case involves a petition for review on certiorari regarding the resolutions of the Court of Appeals dated August 27, 1997, and December 22, 1997.
- The Court upheld the decision of a Panel of Voluntary Arbitrators that dismissed Virginia G. Ramoran for falsifying overtime authorization slips, violating Rule No. 32 of the Company Rules and Regulations of Jardine CMG Life Insurance Company, Inc.
Background Facts
- Virginia G. Ramoran began her employment with Jardine on June 6, 1976, as an accounting clerk and became a junior accountant by 1994.
- Her immediate supervisor was Antonio Robles, the Manager of the Accounting Department.
- On December 7, 1993, Ramoran submitted an overtime authorization slip for alleged overtime work performed on six days in November 1993.
- She received payment for these claims, as well as for additional overtime claimed on December 14, 1993.
Company Rules and Overtime Authorization
- Jardine's policy required that overtime authorization slips pertain to only one date and include specific procedures for submission, including deadlines for forwarding the slips.
- Upon auditing, irregularities in Ramoran's overtime slips were discovered by HRD staff, Yolanda S. Carreon and Amelia F. Castillo, which indicated potential tampering.
Investigation and Findings
- An administrative investigation was initiated on February 1, 1994, where Ramoran denied any intention to falsify and claimed she submitted the slips to catch up on work due to a prior suspension.
- Robles denied approving the overtime slips, asserting that they did not bear his initials and highlighted the incon