Title
Uniwide Sales Warehouse Club vs. National Labor Relations Commission
Case
G.R. No. 154503
Decision Date
Feb 29, 2008
A managerial employee was terminated for loss of trust due to alleged misconduct; SC upheld dismissal, citing just cause and due process compliance.
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Case Summary (G.R. No. 154503)

Background of the Case

  • Amalia P. Kawada began her employment with Uniwide Sales Warehouse Club in 1981 and rose to the position of Full Assistant Store Manager by 1995.
  • Her responsibilities included managing various departments and ensuring compliance with company policies.
  • In 1998, reports of unsatisfactory performance were received regarding Kawada's management, prompting Uniwide to issue several memoranda addressing various allegations against her.

Allegations and Responses

  • The initial memorandum on March 15, 1998, outlined issues such as the commingling of good and damaged items and failure to submit inventory reports.
  • Kawada responded to these allegations on March 23, 1998, but her answers were deemed unsatisfactory by her superior, Vivian Apduhan.
  • Subsequent memoranda detailed further allegations, including allowing unauthorized access to restricted areas and falsifying records.

Medical Issues and Confrontation

  • Kawada sought medical attention for hypertension and was advised to take sick leave.
  • A medical certificate issued by Dr. Zambrano contained an error regarding her surname, leading to a confrontation with Apduhan.
  • Kawada claimed that Apduhan's shouting during this confrontation exacerbated her medical condition, resulting in her collapse.

Legal Proceedings Initiated by Kawada

  • Following the incident, Kawada reported the confrontation to the police and sought legal counsel.
  • On August 3, 1998, she filed a case for illegal dismissal against Uniwide and Apduhan.
  • Apduhan issued a memorandum on August 2, 1998, scheduling a hearing for August 12, 1998, which Kawada did not attend.

Labor Arbiter's Decision

  • The Labor Arbiter dismissed Kawada's complaint for lack of merit on March 9, 1999.
  • Kawada appealed this decision to the National Labor Relations Commission (NLRC), which ruled in her favor, declaring her constructively dismissed.

NLRC's Findings

  • The NLRC found that Kawada was subjected to oppressive treatment and that the successive memoranda constituted harassment.
  • It ruled that Kawada was not afforded due process, as the investigation occurred after her alleged constructive dismissal.

Court of Appeals' Ruling

  • The Court of Appeals affirmed the NLRC's decision, leading to the current petition for review by Uniwide and Apduhan.
  • The primary issue was whether the Court of Appeals erred in sustaining the NLRC's finding of constructive dismissal.

Supreme Court's Review of the Case

  • The Supreme Court emphasized its limited jurisdiction to review errors of law, not fact, but noted the conflicting factual findings between the Labor Arbiter and the NLRC.
  • The Court found insufficient evidence to support the conclusion that Kawada was constructively dismissed.

Definition and Criteria of Constructive Dismissal

  • Constructive dismissal is defined as a situation where continued employment becomes impossible or unreasonable due to employer actions.
  • The Court reiterated that the test for constructive dismissal is whether a reasonable person would feel compelled to resign under the circumstances.

Analysis of Allegations of Harassment

  • The Court found Kawada's claims of harassment to be unsubstantiated and noted that the memoranda were part of management's prerogative to discipline employees.
  • The July 31, 1998 incident was deemed an isolated event and insufficient to establish a pattern of harassment.

Findings on Abandonment of Work

  • The Court ruled that Kawada&...continue reading

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