FACTS:

Ester Asuncion worked as an accountant/bookkeeper for Mabini Medical Clinic. During a routine inspection conducted by Department of Labor and Employment officials, violations of the labor standards law were discovered, including non-coverage from the SSS of the employees. As a result, the company was required to correct these violations. Subsequently, on August 9, 1994, the Medical Director issued a memorandum to Asuncion accusing her of various offenses, such as chronic absenteeism, habitual tardiness, loitering and wasting of company time, and disobedience and insubordination. Asuncion was given two days to explain why she should not be terminated. However, on the morning of August 12, 1994, she submitted her response to the memorandum and was immediately dismissed by the Medical Director for disobedience and failure to timely submit her reply. Asuncion filed a case for illegal termination before the NLRC. The Labor Arbiter ruled in favor of Asuncion, finding that the company failed to present evidence to prove her alleged offenses. However, the NLRC reversed the Labor Arbiter's decision, stating that while the company failed to present evidence of Asuncion's absences and tardiness, she had admitted to these infractions. Asuncion filed a motion for reconsideration, which was denied by the NLRC. Hence, she filed a petition for certiorari before the Supreme Court.

ISSUES:

• Whether petitioner Ester Asuncion was dismissed by Mabini Medical Clinic for a just or authorized cause.

RULING:

• The Supreme Court found that the petitioner was not dismissed for a just or authorized cause due to a paucity of evidence. The employer failed to present credible evidence to support the charges of absenteeism and tardiness against Asuncion. Mere handwritten listings and unsigned computer printouts could not serve as reliable evidence. The petitioner is entitled to reinstatement to her former position with backwages.

PRINCIPLES:

• Evidence in Administrative Proceedings:

  • Administrative bodies are not bound by stringent technical rules of evidence, but the evidence must have rational probative value.

  • Self-serving and unauthenticated documents without probative value should not be considered.

• Due Process in Employment Termination:

  • A worker cannot be dismissed without due process; they must be given a chance to be heard.

  • The employer has the burden of proof to establish just cause for dismissal.

  • Unexplained and unjustified non-presentation of the best evidence suggests intentional suppression, casting doubt on the credibility of the evidence against the employee.

• Resolution of Doubts:

  • In labor disputes, any doubts in the evidence should be resolved in favor of the worker.

  • Employers must provide clear and convincing evidence of any claims regarding just cause for termination.

• Reinstatement and Backwages:

  • If an employee is found to have been wrongfully terminated, they are entitled to reinstatement and backwages.