Case Summary (G.R. No. 166250)
Procedural History
Reyes, alongside two accused colleagues, filed before the Labor Arbiter a complaint for illegal suspension and money claims, later amended to include illegal dismissal. The Labor Arbiter ruled on February 24, 2014 that RBSR illegally dismissed Reyes for want of evidence and due process, awarding backwages, separation pay, benefits, and attorney’s fees. The NLRC reversed on September 30, 2014, allowing the bank’s belated evidence and finding just cause for dismissal. Reyes petitioned the CA, which on July 22, 2016 upheld the NLRC for relaxing procedural rules and for valid dismissal. The CA denied reconsideration on March 8, 2017. Reyes elevated the matter to the Supreme Court by Petition for Review on Certiorari.
Issues Presented
- Whether the CA erred in affirming the NLRC’s reversal of the Labor Arbiter’s decision.
- Whether Reyes was illegally dismissed.
Court’s Analysis
Due Process and Procedural Rules
The Court held that respondents were not denied due process by the Labor Arbiter’s failure to issue summons, because they had obtained a copy of the amended complaint and were twice directed to appear (June 4 and June 19, 2013) yet failed without satisfactory explanation. Under § 3 of the 2011 NLRC Rules, summons serve to inform and furnish copies, but here respondents already possessed the complaint and were duly notified of hearings. Their unexplained absences, despite ample opportunity from June 2013 until the Labor Arbiter’s February 2014 decision, demonstrated negligence rather than lack of notice.
Liberal Interpretation and Its Limits
While labor rules are liberally construed to favor employees, this principle is subject to reason and fair play. Relaxation of procedure benefits workers, not employers who have greater resources and counsel. The Court emphasized that substantial justice does not justify complete disregard for procedural rules. Respondents’ flip‐flop—demanding strict compliance then invoking waiver of rules—undermined their plea for liberal treatment.
Substantive Grounds for Dismissal
The SC found fatal defects in the charges and procedure culminating in Reyes’s termination. He received:
• A March 22, 2013 show‐cause order suspending him preventively for neglect of duty, allowing record access for defense;
• An April 4 notice of administrative case with a hearing date;
• An April 19 show‐cause order alleging participation in misappropriation;
• An April 26 notice of termination citing unexplained offenses without specifics.
These actions failed to satisfy Omnibus Rules, Rule XXIII, Sec. 2:
- First notice must specify exact charges, factual basis, and legal provisions;
- A hearing must follow where the employee may present evidence;
- Final notice must declare grounds established.
The termination letter was vague, did not identify the violated rule or just cause with reasonable particularity, nor record any hearing results.
Moreover, Reyes’s refusal to certify the bank’s report, though
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Factual Background
- Respondent Rural Bank of San Rafael (Bulacan) Inc. (RBSR) is a domestic banking corporation; respondents Veneracion, Sabariaga, Kabiling, Manago, De Guzman, and Quintos are RBSR’s Board members.
- In 2012, stockholders reported discrepancies: original share‐purchase receipts showed prices of ₱250.00–₱275.00, but duplicates retained by RBSR indicated only ₱100.00.
- An internal inquiry confirmed millions of pesos in irregular collections, prompting a Board‐approved “Report on Crimes and Losses” under BSP regulations.
- As Compliance Officer, petitioner Ariel M. Reyes refused to certify the report for lack of independent investigation, material data, and evidence, and asserted he was being pressured.
- RBSR issued two show‐cause orders and placed Reyes on preventive suspension for alleged neglect of duty; scheduled administrative hearings which he did not attend.
- On March 25, 2013, Reyes, together with Bognot and Eusebio (the principal accused), filed a complaint for illegal suspension and money claims, later amended to include illegal dismissal.
Procedural History
- February 24, 2014 – Labor Arbiter Reynaldo V. Abdon found the bank guilty of illegal dismissal, awarded backwages, separation pay, proportionate 13th-month pay, accrued leaves, and attorney’s fees.
- September 30, 2014 – NLRC reversed the Arbiter, applied liberal procedural rules, admitted respondents’ evidence on appeal, and dismissed the complaint for lack of merit.
- March 25, 2015 – Reyes and Bognot petitioned the CA for certiorari, alleging grave abuse of discretion by the NLRC.
- July 22, 2016 – CA affirmed the NLRC Decision, held no abuse of discretion in procedural relaxation, and upheld valid dismissal for just cause.
- March 8, 2017 – CA denied Reyes’s motion for reconsideration.
- March 23, 2022 – Supreme Court resolution on Reyes’s petition for review on certiorari.
Labor Arbiter’s Findings
- Respondents failed to file a Position Paper or submit evidence, and missed at least two scheduled hearings despite having a copy of the amended complaint.
- Complainants’ evidence stood uncontradicted; dismissal was without valid cause and in violation of due process.