G.R. No. 117442-43 - FEM's Elegance Lodging House vs. Murillo

Case Summary (G.R. No. 117442-43)

Applicable Law

The case is governed by the 1987 Philippine Constitution, the Labor Code, and the company’s Disciplinary Rules and Regulations, specifically Coca-Cola's "Red Book."

Employment Background

Anniebel B. Yonzon, employed as an HR Generalist at Coca-Cola Bottlers Philippines, was hired on December 1, 2010, but was dismissed on April 30, 2011, under claims of her inability to meet company standards. This dismissal led her to file a complaint against Coca-Cola for illegal dismissal, which was initially dismissed by the Labor Arbiter but was later reversed by the NLRC, declaring her termination illegal and ordering her reinstatement with backwages.

Subsequent Motions and Claims

Yonzon, following the NLRC's order, sought additional payments including moral and exemplary damages, arguing that her termination was a result of the company's bad faith due to her health issues. After her reinstatement, which was not to her original position, she filed a motion for execution and later pushed for further action because the company failed to act on her prior motions.

Grounds for Dismissal

Yonzon was placed under a 30-day preventive suspension on March 21, 2014, due to an alleged unauthorized disclosure of co-employees' salary information in her motion filed with the NLRC. Coca-Cola found her guilty of serious misconduct that led to her dismissal on April 23, 2014.

Arguments Presented

Yonzon contended that she did not disclose proprietary information to competitors but submitted the information to an arbiter to illustrate her claims of discrimination concerning salaries. Conversely, Coca-Cola asserted that her position as HR Administration Analyst involved trust and confidence regarding sensitive employee data, justifying her dismissal.

Labor Arbiter's Ruling

The Labor Arbiter ruled against Yonzon, asserting that although she did not disclose trade secrets, her unauthorized revelation of salaries was still a breach of company regulations. The Arbiter indicated that allegations of misconduct do not require proof beyond reasonable doubt but must show that the employer had a reasonable basis to lose trust in the employee.

NLRC's Findings

The NLRC overturned the Labor Arbiter's decision, ruling that Yonzon’s action did not constitute a violation of company confidentiality rules. They emphasized the need for disciplinary measures to be fair and not arbitrarily enforced. They also concluded that Yonzon did not pose a threat to the company’s interests with her disclosure.

Court of Appeals Ruling

Upon Coca-Cola's appeal, the Court of Appeals reinstated the Labor Arbiter’s ruling, determining that the disclosure of salaries created a loss of trust and confidence, as Yonzon gained a tactical advantage for her legal battle through her position. The court maintained that positions of responsibility hinge on a trust level that may justify dismissal when breached.

Supreme Court's Decision

The Supreme Court found merit in Yonzon’s petition,