JURISPRUDENCE

Management Prerogative

March 11, 2015

G.R. No. 212054
ST. LUKE'S MEDICAL CENTER, INC.,
vs.
MARIA THERESA V. SANCHEZ,
PERLAS-BERNABE, J.:

“The right of an employer to regulate all aspects of employment, aptly called "management
prerogative," gives employers the freedom to regulate, according to their discretion and best judgment,
all aspects of employment, including work assignment, working methods, processes to be followed,
working regulations, transfer of employees, work supervision, lay-off of workers and the discipline,
dismissal and recall of workers.55 In this light, courts often decline to interfere in legitimate business
decisions of employers. In fact, labor laws discourage interference in employers' judgment concerning
the conduct of their business.56

Among the employer's management prerogatives is the right to prescribe reasonable rules and
regulations necessary or proper for the conduct of its business or concern, to provide certain
disciplinary measures to implement said rules and to assure that the same would be complied with. At
the same time, the employee has the corollary duty to obey all reasonable rules, orders, and
instructions of the employer; and willful or intentional disobedience thereto, as a general rule, justifies
termination of the contract of service and the dismissal of the employee.57 Article 296 (formerly Article
282) of the Labor Code provides:58

Article 296. Termination by Employer. - An employer may terminate an employment for any of the
following causes:

(a) Serious misconduct or willful disobedience by the employee of the lawful orders of his
employer or his representative in connection with his work;”

August 2, 2017
G.R. No. 221493
STERLING PAPER PRODUCTS ENTERPRISES, INC.,
vs.
KMM-KATIPUNAN and RAYMOND Z. ESPONGA,
MENDOZA, J.:

“Time and again, the Court has put emphasis on the right of an employer to exercise its management
prerogative in dealing with its affairs including the right to dismiss its erring employees. It is a general
principle of labor law to discourage interference with an employer's judgment in the conduct of his
business. As already noted, even as the law is solicitous of the welfare of the employees, it also
recognizes the employer's exercise of management prerogatives. As long as the company's exercise
of judgment is in good faith to advance its interest and not for the purpose of defeating or circumventing
the rights of employees under the laws or valid agreements, such exercise will be upheld.34”
Requisites for valid termination/Burden of Proof

July 10, 2017

G.R. No. 212616
DISTRIBUTION & CONTROL PRODUCTS, INC.NINCENT M. TIAMSIC,
vs.
JEFFREY E. SANTOS,
PERALTA, J.:

Thus, two separate inquiries must be made in resolving illegal dismissal cases: first, whether the
dismissal had been made in accordance with the procedure set in the Labor Code;
and second, whether the dismissal had been for just or authorized cause.12

As to substantive due process, this Court, in Agusan Del Norte Electric Cooperative, Inc., et al. v.
Cagampang, et al.,13 held that:

In termination cases, the burden of proof rests upon the employer to show that the dismissal
is for just and valid cause; failure to do so would necessarily mean that the dismissal was illegal. The
employer's case succeeds or fails on the strength of its evidence and not on the weakness of the
employee's defense. If doubt exists between the evidence presented by the employer and the
employee, the scales of justice must be tilted in favor of the latter. Moreover, the quantum of proof
required in determining the legality of an employee's dismissal is only substantial evidence.
Substantial evidence is more than a mere scintilla of evidence or relevant evidence as a
reasonable mind might accept as adequate to support a conclusion, even if other minds,
equally reasonable, might conceivably opine otherwise.14

As to whether or not respondent was afforded procedural due process, the settled rule is that
in termination proceedings of employees, procedural due process consists of the twin requirements of
notice and hearing.29 The employer must furnish the employee with two written notices before the
termination of employment can be effected: (1) the first apprises the employee of the particular acts
or omissions for which his dismissal is sought; and (2) the second informs the employee of the
employer's decision to dismiss him.30 The requirement of a hearing is complied with as long as there
was an opportunity to be heard, and not necessarily that an actual hearing was conducted.31

Serious Misconduct
August 2, 2017
G.R. No. 221493
STERLING PAPER PRODUCTS ENTERPRISES, INC.,
vs.
KMM-KATIPUNAN and RAYMOND Z. ESPONGA,
MENDOZA, J.:

Dismissal from employment on

the ground of serious misconduct

Under Article 282 (a) of the Labor Code, serious misconduct by the employee justifies the employer
in terminating his or her employment.
Misconduct is defined as an improper or wrong conduct. It is a transgression of some established and
definite rule of action, a forbidden act, a dereliction of duty, willful in character, and implies wrongful
intent and not mere error in judgment. To constitute a valid cause for the dismissal within the text and
meaning of Article 282 of the Labor Code, the employee's misconduct must be serious, i.e., of such
grave and aggravated character and not merely trivial or unimportant.22

Additionally, the misconduct must be related to the performance of the employee's duties showing him
to be unfit to continue working for the employer.23 Further, and equally important and required, the act
or conduct must have been performed with wrongful intent.24

To summarize, for misconduct or improper behavior to be a just cause for dismissal, the following
elements must concur: (a) the misconduct must be serious; (b) it must relate to the performance of the
employee's duties showing that the employee has become unfit to continue working for the employer;
and (c) it must have been performed with wrongful intent.25

In the case at bench, the charge of serious misconduct is duly substantiated by the evidence on record.

Failure to Explain

G.R. No. 158583 September 10, 2014

ROSALIE L. GARGOLES,
vs.
REYLITA S. DEL ROSARIO, DOING BUSINESS UNDER THE NAME AND STYLE JAY ANNE'S
ONE HOUR PHOTO SHOP,
BERSAMIN, J.:
“It is truethat every person is entitled to be presumed innocent of wrongdoing. The objective of the
presumption has been to lay the burden of proof onthe shoulders of the alleger of wrongdoing. The
presumption extends tothe petitioner and to every other employee charged with any wrongdoing that
may cause them to be sanctioned, including being dismissed from employment. But the presumption,
which is disputable, by no means excuses the employee charged with wrongdoing from answering
and defending herself once the presumption has been overcome by a showing to the contrary. The
failure of the employee to rebut or disprove the proof of wrongdoing then establishes the charge
against her.12 This is especially truein a case for dismissal grounded on loss of confidence or breach
of trust, in which the employer may proceed to dismiss the erring employee once the employer
becomes morally convinced that she was guilty of a breach of trust and confidence.13 Based on the
record, the petitioner did not sufficiently contradict or rebut the charge of dishonesty.”

“The bottom of the letter contained the handwritten annotation refused to sign, an indication of the
refusal to receive and sign for the letter on the part of the petitioner. Such refusal to receive the letter
containing the notice for her to explain, coupled with her failure to submit her explanation within the
time given in the letter, implied that she waived her right to contest the contents of the letter, thereby
forfeiting her right to respond to the charge against her and to rebut the evidence thereon.”
Social Justice

G.R. No. 188464 July 29, 2015

ALBERTO J. RAZA, Petitioner,
vs.
DAIKOKU ELECTRONICS PHILS., INC. and MAMORU ONO, Respondents.
PERALTA, J.:

While the Court remains invariably committed towards social justice and the protection of the working
class from exploitation and unfair treatment, it, nevertheless, recognizes that management also has
its own rights which, as such, are entitled to respect and enforcement in the interest of simple fair
play.80 The aim is always to strike a balance between an avowed predilection for labor, on the one
hand, and the maintenance of the legal rights of capital, on the other.81 Indeed, the Court should be
ever mindful of the legal norm that justice is in every case for the deserving, to be dispensed with in
the light of established facts, the applicable law, and existing jurisprudence