View full case

ANGELITO P. DELES v. NLRC

FACTS:

The petitioner, a shift supervisor, was employed in a company that operates a pipeline system for petroleum products. During his shift on March 19, 1993, there was a scheduled delivery of kerosene and aviation turbine fuel. The petitioner instructed the chief operator to effect a batch change from the kerosene tank to the aviation fuel tank at a specific reading. However, the operator performed the batch change at a different reading, resulting in the mixing of some aviation fuel with the kerosene.

After conducting an investigation, the company found the petitioner, the operator, and the gauger guilty of neglect of duty. The petitioner received a three-month suspension, while the operator was dismissed, and the gauger was suspended for one and a half months. Dissatisfied with his suspension, the petitioner filed a complaint challenging its legality.

During the suspension period, it was discovered that the petitioner had allowed unauthorized individuals into a restricted area and tampered with operating equipment. Subsequently, the company conducted another investigation, which led to the termination of the petitioner's employment. The company cited violations of safety regulations and loss of trust and confidence as the grounds for the termination.

The petitioner amended his complaint to include a charge of illegal dismissal. The labor arbiter dismissed the complaint, but the National Labor Relations Commission (NLRC) modified the decision and awarded an indemnity for the company's failure to comply with due process requirements.

ISSUES:

  1. Whether or not the NLRC gravely abused its discretion in affirming the labor arbiter's decision based on the bare and self-serving allegations of the respondent company.

  2. Whether or not the NLRC gravely abused its discretion in disregarding the belatedly surfaced charges against the petitioner as an apparent instance of harassment.

  3. Whether or not the petitioner was illegally suspended and dismissed.

  4. Whether or not loss of trust and confidence is a valid ground for dismissing an employee.

  5. Whether or not the petitioner, a managerial employee, committed acts inimical to the interest of his employer.

RULING:

  1. The Supreme Court ruled that the NLRC did not commit grave abuse of discretion in affirming the labor arbiter's decision. Regarding the legality of petitioner's suspension, the Court held that the employer has the prerogative to regulate all aspects of employment, including the discipline and dismissal of workers, as long as it is done in accordance with company rules and regulations. In this case, the petitioner's suspension was found to be reasonable and appropriate.

  2. With regards to the legality of the petitioner's dismissal, the Court explained that it is not within its authority to re-evaluate the evidence and substitute its own findings of fact for those of the labor tribunal. The Court can only review NLRC decisions for want of jurisdiction or grave abuse of discretion. In this case, there was no showing that the NLRC committed grave abuse of discretion in affirming the labor arbiter's finding that the respondent company had sufficient basis to lose trust and confidence in the petitioner.

  3. Yes, loss of trust and confidence is a valid ground for dismissing an employee, as provided for in the Labor Code. In this case, the petitioner, a managerial employee, held a position of trust and confidence and committed acts that betrayed the trust and confidence reposed on him by tampering with sensitive equipment and jeopardizing the safety of the public.

  4. Yes, the petitioner committed acts inimical to the interest of his employer by tampering with sensitive equipment, which exposed the terminal complex and the residents in adjacent communities to the danger of a major disaster. The petitioner's admitted infraction and past violation of safety regulations were sufficient grounds for his dismissal.

PRINCIPLES:

  • The right of an employer to regulate all aspects of employment, including the discipline and dismissal of workers, is well settled and is called management prerogative.

  • In reviewing NLRC decisions, the Supreme Court is confined only to issues of want of jurisdiction and grave abuse of discretion on the part of the labor tribunal.

  • The Supreme Court cannot re-evaluate the evidence and substitute its own findings of fact for those of the labor tribunal.

  • Loss of trust and confidence is a valid ground for terminating employment, particularly for employees in positions of trust and responsibility.

  • Mere existence of a basis for believing that a managerial employee has breached the trust of his employer is sufficient for his dismissal, without the need for proof beyond reasonable doubt.

  • An employer must observe legal procedure prior to the termination of an employee, which includes giving the employee ample opportunity to present his/her side and defend against the charges.