RENO FOODS, INC. v.

NAGKAKAISANG LAKAS NG MANGGAGAWA (NLM)- Capors acquittal in the criminal case one grounded on the existence of
KATIPUNAN
GR 164016 / MARCH 15, 2010 / DEL CASTILLO, J./LABOR /MPESQUIVIAS
NATURE Petition for review on certiorari
PETITIONERS Reno Foods, Inc., Vicente Khu
RESPONDENTS Nagkakaisang Lakas ng Manggagawa (NLM)-Katipunan on behalf of
member Nenita Capor
SUMMARY. Capor was caught by the guard on duty at Reno with six canned goods in her bag.
Reno terminated her employment, and charged her with qualified theft. The NLM-Katipunan
filed a complaint praying for the payment of full backwages. The SC denied the prayer, saying
that the act of theft is serious misconduct, and that separation pay is only warranted when
there is no just cause for the termination.
DOCTRINE. There is no legal or equitable justification for awarding financial assistance to an
employee who was dismissed for stealing company property.
FACTS.
Reno Foods is a manufacturer of canned meat products. Vicente Khu is the president.
Nenita Capor was an employee of Reno.
A guard on duty found six Reno canned goods wrapped in nylon leggings inside
Capors fabric clutch bag. (The other contents of the bag were money and a small
medicine container.)
Reno gave Capor several opportunities to explain her side. After they sent her a
Notice of Termination, she was given an opportunity for reconsideration through a
labor-management grievance conference. However, Reno did not find reason to
change its decision to terminate her employment.
Afterwards, Reno filed a complaint against Capor for qualified theft. A Resolution
was issued finding probable cause for the crime charged.
The NLM-Katipunan filed on behalf of Capor a complaint for illegal dismissal, and
prayed that she be paid her full backwages as well as moral and exemplary
damages.
LA: guilty of serious misconduct (cause for termination); not entitled to separation
pay. NLRC affirmed, added award for financial assistance. CA affirmed NLRC, and
stressed the primacy of laborers welfare.
On the date that the CA issued its Decision, Capor filed a Manifestation that she was
acquitted of the charge against her (due to lack of substantial evidence on Renos
part).
reasonable doubt will not preclude the determination in a labor case that she
is guilty of the acts inimical to Renos interests.
Criminal cases require proof beyond reasonable doubt while labor disputes require
only substantial evidence (relevant evidence as a reasonable mind might accept as
adequate to justify a conclusion).
The lower courts found substantial evidence to conclude that Capor had been
validly dismissed for dishonesty or serious misconduct.
RE SEPARATION PAY: Separation pay is only warranted when the cause for
termination is not attributable to the employees fault (Art. 283 and 284), as
well as illegal dismissal in which reinstatement is no longer feasible.
Jurisprudence has classified theft of company property as a serious misconduct.
It is true that there have been instances when the Court awarded financial assistance
to employees who were terminated for just causes, on grounds of equity and social
justice. But in those cases, the Court recognized the harsh realities faced by
employees that forced them to violate company policies.
But when the employee commits an act of dishonesty, depravity or iniquity, the
grant of financial assistance is misplaced compassion. It is tantamount not only
to condoning a patently illegal or dishonest act, but an endorsement thereof. It
will be an insult to all the laborers who, despite their economic difficulties,
strive to maintain good values and moral conduct.
Length of service (Capor served for 39 years) and a previously clean employment
record cannot simply erase the gravity of the betrayal exhibited by a malfeasant
employee.
DECISION.
Petition granted.
NOTES.
There is no legal or equitable justification for awarding financial assistance to
an employee who was dismissed for stealing company property. Social justice
and equity are not magical formulas to erase the unjust acts committed by the
employee against his employer.

ISSUES & RATIO.

WON financial assistance should be granted to an employee validly dismissed for
theft of company property NO :(