Aboc v. Metrobank

G.R. No. 170542-43, 176460 (December 13, 2010)

Antonio A. Aboc was dismissed for misconduct; court upheld the decision, stressing loyalty and procedure.

Facts:

Antonio A. Aboc was employed as a Regional Operations Coordinator at Metropolitan Bank and Trust Company (Metrobank) in Cebu City, having started his career with the bank in 1988. He had a commendable employment record, receiving promotions and merit increases due to his satisfactory performance. However, on January 29, 1998, he received an inter-office letter from Metrobank requiring him to explain his involvement in the lending activities of his immediate supervisor, Wynster Y. Chua, the Branch Manager. Aboc admitted to performing ministerial tasks for Chua, such as preparing deposit slips and typing statements, but denied any significant involvement in Chua's lending business.

Metrobank alleged that Aboc, along with Chua and other employees, organized a credit union named Cebu North Road Investment (CNRI) without the bank's knowledge, using its premises and resources. They also created another credit union, First Fund Access (FFA), which operated under fictitious names. Metrobank claimed that Aboc solicited clients, including bank customers, to invest in these credit unions, which directly competed with Metrobank's business. Following an investigation, Metrobank dismissed Aboc on February 12, 1998, citing serious misconduct and breach of trust.

Aboc filed a complaint for illegal dismissal and damages against Metrobank. The Labor Arbiter ruled in his favor, declaring the dismissal illegal and ordering reinstatement and payment of back wages. The National Labor Relations Commission (NLRC) later reversed this decision, finding Aboc guilty of serious misconduct and breach of trust, and ordered Metrobank to pay him certain monetary awards. Both parties appealed to the Court of Appeals, which affirmed the NLRC's decision regarding the validity of Aboc's dismissal but also upheld the monetary awards.

Legal Issues:

  1. Whether the Court of Appeals erred in ruling that Aboc was validly dismissed by Metrobank.
  2. Whether the Court of Appeals erred in ruling that Metrobank was liable to pay the monetary award claimed by Aboc.

Arguments:

Position of Aboc:

  • Metrobank's petition to the Court of Appeals was filed out of time and did not comply with procedural requirements.
  • His actions did not constitute serious misconduct or breach of trust, as credit unions were not explicitly prohibited by Metrobank.
  • He was deprived of due process due to the oppressive nature of the investigation conducted by Metrobank.

Position of Metrobank:

  • The filing of its petition was timely, and any delay was minimal and should not be fatal.
  • Aboc's actions, including organizing credit unions and soliciting clients, constituted serious misconduct and a breach of trust.
  • The monetary awards granted to Aboc were unwarranted, as they exceeded what was ordered by the Labor Arbiter.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the decision of the Court of Appeals, finding no reason to disturb its ruling. It held that:

  1. Timeliness of Metrobank's Petition: The Court found that Metrobank's petition was timely filed, and even if there was a slight delay, it should not be a basis for dismissal. The Court emphasized that litigation should be decided on merits rather than technicalities.

  2. Validity of Dismissal: The Court upheld the findings of the NLRC and the Court of Appeals that Aboc's actions constituted serious misconduct and a breach of trust. His involvement in the credit unions, which competed with Metrobank's business, was deemed highly irregular. The Court noted that Aboc's claim of being an "unwilling participant" was not credible given the evidence of his active involvement.

  3. Due Process: The Court ruled that Aboc was afforded due process, as he was given notice and an opportunity to explain his side during the conference held by Metrobank. A formal trial-type hearing was not necessary for due process to be satisfied.

  4. Monetary Awards: The Court agreed with the Court of Appeals that the monetary awards granted to Aboc were warranted. Since Metrobank opted for payroll reinstatement, Aboc was entitled to receive his wages and benefits during the period of appeal.

Significant Legal Principles Established:

  • The burden of proof in termination cases lies with the employer to demonstrate just cause for dismissal.
  • Substantial evidence is required to support claims of serious misconduct and breach of trust.
  • Due process in administrative proceedings does not always require a formal hearing; an opportunity to be heard is sufficient.
  • An employer's decision to reinstate an employee pending appeal obligates them to pay wages and benefits during that period.