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DIOSDADO V. RUFFY v. NLRC

FACTS:

The complainant, an employee of the respondent, was assigned in the Materials and Supply Section. On November 3, 1984, the complainant issued twenty-five sets of roller bearings to a person who signed his name as "Role". These bearings were never received by the requisitioning section. It was discovered that the bearings were sold by another employee to a third party. The complainant was asked if Alfredo Role, also an employee, received the bearings but he could not remember. As a result, the complainant was dismissed on December 31, 1984, for breach of trust. The labor arbiter ruled that the dismissal was legal but awarded the complainant financial assistance. The National Labor Relations Commission (NLRC) affirmed the decision. The petitioner appealed to the NLRC, arguing that the dismissal was without due process. The NLRC dismissed the appeal. The petitioner filed a petition for certiorari, alleging grave abuse of discretion on the part of the NLRC. The Supreme Court granted the petition, ruling that the petitioner was not given ample opportunity to be heard before his dismissal. The Court emphasized that the procedure set forth by the law need to be obeyed according to its spirit, as a due process measure.

ISSUES:

  1. Whether the petitioner was given ample opportunity to defend himself in accordance with the procedure under Section 13 of Batas Blg. 130.

  2. Whether the dismissal of the petitioner was valid under the law.

RULING:

  1. The Court held that the petitioner was not given ample opportunity to defend himself as required by the law. Although the petitioner was given the opportunity to air his side after his termination, the fact remains that he had already been dismissed before the opportunity was given. The law requires that the procedure of notice, hearing, and judgment be followed in the natural sequence, and it must be observed before dismissal can be validly effected.

  2. The Court ruled that the dismissal of the petitioner was not valid under the law. The process set forth by Section 13 of Batas Blg. 130 must be followed as a due process measure. The petitioner's termination, even if effective on a later date, did not provide him with ample opportunity to prepare for his defense. The Court emphasized that "fire the employee, and let him explain later" is not in accordance with the spirit of the law.

PRINCIPLES:

  • The procedure under Section 13 of Batas Blg. 130, which includes notice, hearing, and judgment, must be followed before a valid dismissal can be effected.

  • The process set forth by the law need not be strictly followed according to its letter, but it must be followed according to its spirit as a due process measure.

  • "Ample opportunity" to defend oneself means every kind of assistance that management must provide to the employee to enable him to adequately prepare for his defense.