Political Law

Manila Electric Company vs National Labor Relations Commission (1989)

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G.R. No. 78763 – 175 SCRA 277 – Political Law – Constitutional Law – Due Process; Administrative Bodies

Labor Law – Labor Relations – Termination of Employment – Grounds of Termination; when offset

Apolinario Signo was employed by the Manila Electric Company (Meralco) as supervisor-leadman since 1963. During his 20 year-tenure of service in said company, he had been commended twice for honesty. However, one time in 1981, he facilitated an “illegal” connection to the house of a certain Fernando De Lara; the latter received “free” service of electricity for a year since he was not billed for Meralco’s services. This irregularity was later discovered and so in 1983, Signo was fired by Meralco on the ground of breach of trust and loss of confidence which are grounds for termination under the Labor Code.

Signo filed a case for illegal dismissal and for backwages. The Labor Arbiter ruled that though there is breach of trust on the part of Signo, dismissal is too harsh a penalty considering that Signo has been employed by Meralco for 20 years; that except for that one time infraction, Signo had a clean slate with Meralco. On appeal, The National Labor Relations Commission (NLRC) affirmed the factual findings of the Labor Arbiter. Meralco questioned the validity of the NLRC decision before the Supreme Court via a petition for certiorari under Rule 65 of the Rules of Court.

ISSUE: Whether or not the findings of the NLRC, an administrative body, is reviewable by the Supreme Court in this case.

HELD: No. The Supreme Court sustained the decision of the NLRC. Well-established is the principle that findings of administrative agencies which have acquired expertise because their jurisdiction is confined to specific matters are generally accorded not only respect but even finality. Judicial review by this Court on labor cases does not go so far as to evaluate the sufficiency of the evidence upon which the proper labor officer or office based his or its determination but is limited to issues of jurisdiction or grave abuse of discretion. No such issues of jurisdiction or grave abuse of discretion is present in the case at bar.

Further, notwithstanding the existence of a valid cause for dismissal, such as breach of trust by an employee, nevertheless, dismissal should not be imposed, as it is too severe a penalty if the latter has been employed for a considerable length of time in the service of his employer. Reinstatement of respondent Signo is proper in the instant case, but without the award of backwages, considering the good faith of Meralco in dismissing him.

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