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MANILA WATER COMPANY v. CARLITO DEL ROSARIO

FACTS:

This case involves a petition filed by Manila Water Company, disputing the decision of the Court of Appeals regarding the dismissal of their employee, Carlito Del Rosario. Del Rosario, who was hired by MWSS and later absorbed by Manila Water, was found to be involved in pilferage and sale of water meters along with a co-employee. Upon discovering this, Manila Water dismissed Del Rosario from employment. He subsequently filed a complaint for illegal dismissal, claiming coercion during his admission of guilt. Although the Labor Arbiter dismissed the complaint, separation pay was awarded. The NLRC initially dismissed Manila Water's appeal on technical grounds but the Court of Appeals reversed this decision. Manila Water argues that an employee who is separated for serious misconduct is not entitled to separation pay.

ISSUES:

  1. Whether the Court of Appeals erred in granting separation pay to an employee dismissed for serious misconduct.

RULING:

  1. The Supreme Court ruled that the Court of Appeals erred in awarding separation pay to Carlito Del Rosario, as his dismissal was due to serious misconduct, and established jurisprudence provides that employees dismissed for serious misconduct or acts reflecting on their moral character are not entitled to separation pay.

PRINCIPLES:

  1. Separation Pay and Serious Misconduct As a general rule, an employee dismissed for any of the just causes enumerated under Article 282 of the Labor Code, including serious misconduct, is not entitled to separation pay.

  2. Exceptions for Social Justice Separation pay can be granted as a measure of social justice or on equitable grounds only in instances where the dismissal is for causes other than serious misconduct or acts that reflect on the employee's moral character.

  3. Doctrine on Awarding Separation Pay Established doctrines state that separation pay shall not be awarded to employees dismissed for serious misconduct, willful disobedience, gross and habitual neglect of duty, fraud, willful breach of trust, commission of a crime against the employer or his family, or those reflecting on the employee's moral character.

  4. Prohibition on Compensating Misconduct Courts should be cautious in granting financial benefits to employees dismissed for serious offenses as it would unjustly reward wrongful behavior and undermine the principle of social justice.

  5. No Further Relief for Non-Appealing Party A party who does not appeal cannot obtain any affirmative relief other than what was granted in the appealed decision.

References

  • Philippine Long Distance Telephone Company v. NLRC

  • Toyota Motor Phils. Corp. Workers Association (TMPCWA) v. National Labor Relations Commission

  • Central Pangasinan Electric Cooperative, Inc. v. National Labor Relations Commission