Case Summary (G.R. No. 212054)

Background of the Case

• Maria Theresa V. Sanchez was employed as a Staff Nurse by St. Luke's Medical Center, Inc. (SLMC) on June 29, 2009.
• She was terminated on July 6, 2011, for allegedly violating SLMC's Code of Discipline, specifically regarding acts of dishonesty.
• The incident leading to her dismissal occurred on May 29, 2011, when security personnel found medical supplies in her bag during a routine inspection.

Incident and Initial Investigation

• Sanchez was found with various medical items, which she requested to return to the treatment room but was instead taken to the In-House Security Department.
• She submitted an Incident Report and a handwritten letter of apology, admitting to taking the items but claiming it was unintentional.
• An initial investigation by SLMC concluded that Sanchez had intentionally taken the items, leading to her preventive suspension on June 3, 2011.

Labor Arbiter's Ruling

• The Labor Arbiter ruled on May 27, 2012, that Sanchez was validly dismissed for theft, as her actions constituted serious misconduct.
• The Arbiter emphasized that the items taken were not her property and that her admission of wrongdoing indicated intent to commit an act of dishonesty.

NLRC's Reversal of the Arbiter's Decision

• The NLRC reversed the Labor Arbiter's ruling on November 19, 2012, declaring Sanchez's dismissal illegal.
• The NLRC noted that hoarding medical supplies was a common practice among nurses in the Pediatric Unit and that Sanchez's actions were not for personal gain.
• It concluded that the penalty of dismissal was excessive, given that Sanchez had already served a one-month preventive suspension.

Court of Appeals' Affirmation

• The Court of Appeals upheld the NLRC's decision on November 21, 2013, stating that Sanchez's actions did not constitute serious misconduct.
• The CA highlighted that the items were not SLMC property and that the retention of excess supplies was tolerated by management.
• It also noted that Sanchez's demeanor during the incident indicated a lack of intent to commit theft.

Supreme Court's Ruling

• The Supreme Court found that Sanchez was validly dismissed for willful disobedience of SLMC's Code of Discipline.
• The Court emphasized that Sanchez's admission in her handwritten letter demonstrated her awareness of th...continue reading