Valenzuela v. Caltex

G.R. No. 169965-66 (December 15, 2010)

SC rejected Carlos V. Valenzuela's illegal dismissal appeal but ordered Caltex to pay unpaid salaries.

Facts:

Petitioner Carlos V. Valenzuela was employed by respondent Caltex Philippines, Inc. in March 1965 as a laborer, later becoming a machine operator and subsequently a messenger and aviation attendant. After 22 years in the Manila Aviation Service, he was transferred to the Lapu-Lapu Terminal as part of a penalty for allegedly failing to service an aircraft's fuel needs, which he denied. In his new role, he took on various responsibilities, including those of a warehouseman after the previous warehouseman retired.

On November 23, 1999, a spot operational audit revealed a significant inventory shortage of P823,100.49 at the Lapu-Lapu City District Office. Valenzuela was required to explain this shortage and was preventively suspended pending an administrative investigation to prevent further losses and possible tampering with evidence. The investigation included hearings on December 15, 1999, and January 18, 2000, where Valenzuela was present with legal representation.

Following the investigation, Caltex found Valenzuela liable for gross and habitual neglect of duties, failure to perform month-end inventory duties, not investigating stock shortages, and committing fraud. Consequently, his employment was terminated.

Valenzuela filed a complaint for illegal dismissal with the National Labor Relations Commission (NLRC), which initially ruled in his favor, declaring the dismissal illegal and awarding him separation pay. Caltex appealed this decision to the Court of Appeals (CA), which reversed the NLRC's ruling and reinstated the Labor Arbiter's original decision dismissing Valenzuela's complaint.

Legal Issues:

  1. Did the CA err in giving due course to the petition for certiorari filed by Caltex despite alleged procedural defects?
  2. Was Valenzuela's dismissal valid and supported by sufficient evidence?

Arguments:

Petitioner (Valenzuela):

  • Argued that the CA's acceptance of Caltex's petition for certiorari was flawed due to procedural lapses, including the lack of a proper verification and certification against forum shopping and failure to submit relevant documents.
  • Contended that there was no legal basis for his dismissal, emphasizing that he had previously raised concerns about being overworked and that the duties assigned to him were excessive.

Respondent (Caltex):

  • Countered that there were indeed two certifications against forum shopping, one from its representative and another from Leodegario Jacinto, who was authorized to sign on behalf of Caltex.
  • Asserted that the CA's request for additional documents did not indicate a procedural defect and that the termination was justified based on evidence of Valenzuela's gross and habitual neglect of duties.

Court's Decision and Legal Reasoning:

The Supreme Court denied Valenzuela's petition, affirming the CA's decision.

  1. Procedural Issues: The Court found that Caltex had submitted the necessary certifications against forum shopping, and the absence of certain documents did not warrant outright dismissal of the petition. The Court emphasized that the determination of relevant documents is primarily the responsibility of the petitioner, and the CA acted within its discretion in requesting additional documents.

  2. Merits of Dismissal: The Court upheld the findings of the Labor Arbiter and the CA that Valenzuela's dismissal was justified. It noted that there was substantial evidence supporting the claims of gross and habitual neglect of duties, including Valenzuela's failure to address previous inventory shortages and his manipulation of stock records. The Court reiterated that under Article 282 of the Labor Code, gross and habitual neglect, as well as fraud or willful breach of trust, are valid grounds for termination.

The Court also addressed the issue of preventive suspension, stating that while Valenzuela was suspended for a period exceeding 30 days without pay, he was entitled to his salary and benefits for the period from December 26, 1999, to January 21, 2000, prior to his dismissal.

Significant Legal Principles Established:

  • The importance of proper verification and certification against forum shopping in petitions for certiorari.
  • The sufficiency of evidence required to justify termination based on gross and habitual neglect of duties and breach of trust.
  • The rights of employees regarding preventive suspension and entitlement to wages during extended periods of suspension.