Case Summary (G.R. No. 124348)
Allegations of Misconduct
The audit revealed discrepancies in Sanchez's transactions, specifically the padding of 200 cases of "empties" during the "load in" process, leading to an unaccounted excess valued at P13,200.00. Additionally, it was found that 331 cases of "empties," worth P22,252.00, were improperly recorded on his load sheet. As a result, he was charged with several violations, including failure to remit collections and borrowing company property without proper authorization.
Admission of Policy Violation
In a letter dated July 18, 1990, Sanchez acknowledged that he borrowed 200 cases of "empties" from a dealer to cover medical expenses for his wife. This admission, combined with the audit findings, formed the basis for the administrative charges against him. Following the completion of procedural due process, he was terminated from his employment on November 16, 1990.
Legal Proceedings Initiated by Sanchez
On April 12, 1993, Sanchez filed a complaint for illegal dismissal against PEPSI-COLA. The Labor Arbiter ruled in favor of Sanchez, ordering his reinstatement with back wages and additional damages. The Arbiter concluded that there was insufficient evidence to support the allegations against him, emphasizing that the charges lacked the necessary substantiation.
NLRC Ruling and Appeal
On November 22, 1995, the NLRC reversed the Labor Arbiter’s decision, dismissing Sanchez’s complaint for lack of merit, but awarded him separation pay. The NLRC found that the grounds for his dismissal were warranted due to the breach of trust represented by his admission and actions.
Contentions of Sanchez
Sanchez argued that his dismissal was unjustified, citing a lack of evidence to substantiate the company’s claims. He emphasized the stringent security measures in place at the company’s plant, which he contended made it implausible for him to have committed the alleged violations without detection. Moreover, he contended that his borrowing of "empties" could only be deemed a violation if a formal complaint was lodged by the dealer, which had not occurred.
Defense by PEPSI-COLA
Conversely, PEPSI-COLA maintained that Sanchez's actions constituted a breach of trust, justifying his dismissal. The company pointed to his admission as critical evidence of his misconduct, asserting that his failure to properly account for sales revenue provided a reasonable basis for management to lose trust in him. They reinforced that employees in positions of responsibility must abide by strict accountability standards given their access to significant company assets.
Legal Principles on Termination
The court acknowledged that the loss of trust and confidence is a
...continue readingCase Syllabus (G.R. No. 124348)
Case Overview
- The case involves Dominador Sanchez, a long-term salesman for Pepsi-Cola Products Philippines, Inc., who was dismissed after 23 years of service for alleged violations of company rules leading to loss of trust and confidence.
- The dismissal was contested as illegal, leading to a labor complaint filed by Sanchez.
Background of the Case
- Dominador Sanchez worked as a route salesman for Pepsi-Cola since 1976, with responsibilities including marketing, merchandising, collection of sales proceeds, granting credit extensions, and delivering products.
- An audit in June 1990 revealed discrepancies in Sanchez's transactions for April and May 1990, including the padding of 200 cases of "empties" during the load-in process, which indicated potential theft or dishonesty.
Charges Against Sanchez
- Sanchez faced administrative charges for:
- Failure to account for all collections from route sales at the end of each day.
- Borrowing "empties" and "fulls" from dealers.
- Engaging in stealing and other forms of dishonesty.
- These violations were classified under Group H of company regulations, which warranted dismissal.
Admission and Dismissal
- In a letter dated July 18, 1990, Sanchez admitted to borrowing 200 cases of "empties" from a dealer to cover medical expenses for his wife.
- Following a due process procedure, Sanchez was dismissed from service on November 16, 1990.
Labor Arbiter's Decision
- On