Case Summary (G.R. No. 170646)
Factual Background
Ma. Ligaya B. Santos was hired on December 5, 1989, by Litton Mills, a textile manufacturing company. She was tasked within the Plant Administration and Services Department, where she was involved in the sale of used sludge oil and other waste materials. On September 28, 2002, Atty. MariAo directed her to provide a written explanation for allegedly engaging in unauthorized arrangements with a waste buyer, Leonardo A. Concepcion. The accusation included demands for payments in exchange for purchases and threats to delay the release of materials. Santos denied these allegations in her reply and stated that money received from Concepcion was a loan repayment, arguing her actions were personal and did not contravene company policies.
Administrative Investigation and Dismissal
Petitioner Santos was subjected to an administrative investigation on October 4, 2002. Represented by union officers, she claimed that she had no authority to intimidate any client. On October 11, 2002, she received a Letter of Termination, citing her acceptance of money in violation of company policy. In response, she subsequently filed a complaint for illegal dismissal seeking damages and attorney fees.
Ruling by Labor Arbiter
The Labor Arbiter resolved the complaint on November 28, 2003, dismissing it for just cause based on the perceived violation of company discipline. The Arbiter held that the pending criminal case for extortion against Santos indicated sufficient grounds for her dismissal, concluding that her actions undermined the company's interests. The dismissal of her damage claims followed similarly due to lack of merit.
National Labor Relations Commission Decision
Upon appealing to the NLRC, Santos contended that the Labor Arbiter erroneously relied on criminal proceedings for a finding of lawful dismissal. However, the NLRC upheld the Arbiter's ruling, emphasizing that despite Santos’s acquittal in criminal court, her actions constituted a serious infraction of company policy. Consequently, her dismissal was affirmed by the NLRC in resolutions dated August 27 and November 30, 2004.
Court of Appeals' Resolution
Santos pursued a Petition for Certiorari with the Court of Appeals (CA), which was ultimately dismissed on March 10, 2005, for procedural deficiencies. Specifically, the CA noted the failure to provide actual addresses for all parties and the lack of proper verification regarding pending cases. Subsequently, her Motion for Reconsideration was also denied on November 29, 2005, based on similar procedural missteps.
Issues Raised
In her Petition, Santos argued that the CA exhibited hostility in dismissing her petition despite corrections made for compliance with procedural norms. She also challenged the findings of the NLRC and Labor Arbiter
...continue readingCase Syllabus (G.R. No. 170646)
Case Citation
- 667 Phil. 640
- G.R. No. 170646
- Date of Decision: June 22, 2011
Court and Justices
- Court: Supreme Court of the Philippines
- Authoring Justice: Del Castillo, J.
- Concurring Justices: Corona, C.J. (Chairperson), Leonardo-De Castro, Perez, and Mendoza, JJ.
Background of the Case
- The case involves a Petition for Review on Certiorari filed by Ma. Ligaya B. Santos against Litton Mills Incorporated and Atty. Rodolfo MariAo, challenging several resolutions from lower courts.
- The petitioner sought to overturn the dismissal of her complaint for illegal dismissal by the National Labor Relations Commission (NLRC) following her termination from employment.
Factual Antecedents
- Employment History: Petitioner, Ma. Ligaya B. Santos, was hired on December 5, 1989, by Litton Mills, a company engaged in textile manufacturing.
- Incident Leading to Termination:
- On September 28, 2002, Atty. Rodolfo MariAo, the personnel manager, directed Santos to explain her alleged involvement in an unauthorized arrangement with a waste buyer, Leonardo A. Concepcion.
- Allegations included demanding money from Concepcion and threatening to delay the release of purchased materials.
- Santos was placed under preventive suspension pending investigation.
- Defense: In her response, Santos denied the allegations, asserting that the money received from Concepcion was repayment for a loan to his wife and not related to her employment duties.
- Criminal Complaint: A criminal complaint for robbery/extortion was subsequently filed against her.
Labor Arbiter's Ruling
- Decision Date: November 28, 2003
- Outcome: Dismissal of Santos' complaint for illegal dismissal.
- Findings:
- Just cause for dismissal was esta