ERIC DELA CRUZ VS COCA-COLA BOTTLERS PHILS. INC.

ERIC DELA CRUZ

VS

COCA-COLA BOTTLERS PHILS. INC.
594 SCRA 761 (2009)

Acts by employees which are inimical to the employer’s interest are deemed willful breach of the trust and confidence reposed in them.

Raymund Sales, a salesman of Coca-Cola Bottlers Phils. Inc (Coca-Cola), figured an accident while driving a vehicle he was not authorized to use. Sales was hospitalized and was observed that he was under the influence of liquor at the time of the accident and was included in the police blotter.

Respondent Coca-Cola discovered that Sales’ co-employees secured a police report and medical certificate which omitted the fact that Sales was under the influence of alcohol. Coca-Cola required Sales’ Supervisors John Espina, Raul M. Lacuata (Lacuata), and Eric dela Cruz (dela Cruz), to explain why no disciplinary action be taken against them. Espina denied the fact that he altered the documents. Petitioner Dela Cruz said that he just asked for a copy of the police report one Melvin Asuncion. And lastly, Petitioner Lacuata said that he has no participation in the alleged alteration because he only picked-up the medical certificate from the Hospital. Further investigation shows that they conspired to alter the medical certificate and the police report. After such finding they were dismissed from employment. Espina, Lacuata and dela Cruz filed separate complaints for illegal dismissal with the contention that the alleged altering of documents is work related and is a willful breach of confidence.

The Labor Arbiter dismissed Espina’s complaint for lack of merit. Dela Cruz was found to be illegally dismissed. Lacuata was found to be at fault for doing nothing to stop Espina from obtaining false police and medical reports. The respondent Coca-Cola was ordered to reinstate dela Cruz and pay both petitioners dela Cruz and Lacuata their respective back wages, 13th month pay and separation pay. On appeal, the National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision but deleted the award of moral damages in favor of dela Cruz. Its motion for reconsideration having been denied, respondent filed a Petition for Certiorari before the Court of Appeals (CA). The CA set aside the NLRC decision and held that petitioners Lacuata and dela Cruz were validly dismissed.

ISSUE:
Whether or not Lacuata and dela Cruz were validly dismissed on the grounds of altering the medical certificate and police report of Sales

HELD:
Dela Cruz et al. contend, however, that for loss of trust and confidence to be a ground for termination of employment, it must be willful and must be connected with the employee’s work.

By obtaining an altered police report and medical certificate, Dela Cruz et al. deliberately attempted to cover up the fact that Sales was under the influence of liquor at the time the accident took place. In so doing, they committed acts inimical to respondent’s interests. They thus committed a work-related willful breach of the trust and confidence reposed in them.

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