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Pamplona Plantation Co. vs. Ramon Acosta et al.

G.R. No. 153193 (2006) PHSC 1157 (Dec. 6, 2006)

Statement of the problem

What is the extent of the liability of the management of Pamplona Plantation Co. Inc. in the
alleged underpayment of its employees and the illegal dismissal of two others?

Statement of objectives

- To determine if Pamplona Plantation Co. Inc. should be held liable for underpaying the 66
- To find out if Pamplona Plantation Co. Inc. illegally dismissed two of its employees, Pedro
Emperado and Joselito Tinghil
- To determine if project manager Jose Luis Bondoc should also be held jointly and severally
liable in the underpayment and illegal dismissal cases

Areas for consideration

Sixty-six individuals filed a case with the Labor Arbiter against Pamplona Plantation Co. Inc.
for alleged underpayment of overtime pay, premium pay for rest day and holiday, service
incentive leave pay, and 13th month pay. They sought payment for damages and attorney's
fees. In their complaint, they claimed that they were regular rank and file employees of
Pamplona Plantation Co. Inc. The company denied this, however, saying some of them were
seasonal employees and contractors, while some were hired under the "pakyaw" system. The
company also alleged that some of the complainants were hired by Pamplona Plantation
Leisure Corp., a separate company.

The Labor Arbiter, in a decision dated Sept. 30, 1998, held Pamplona Plantation Co. Inc. and
manager Jose Luis Bondoc liable for underpayment, as complainants were regular
employees of the company. They were likewise found guilty of the illegal dismissal of two of
the complainants -- Joselito Tinghil and Pedro Emperado.

The National Labor Relations Commission, however, reversed the Labor Arbiter's decision in
a ruling dated June 30, 2000. NLRC said the complaint should have been directed against
Pamplona Plantation Leisure Corp. since the complainants' affidavits said their tasks referred
to those that they did "in the golf course."

The Court of Appeals, on Nov. 26, 2001, vacated and set aside the NLRC's dismissal, in turn
reinstating the Labor Arbiter's decision, with the modification that wage differentials should be
awarded to only 22 of the 66 complainants. The appellate court likewise deleted the award of
attorney's fees and the finding of illegal dismissal of Pedro Emperado.

Pamplona Plantation Co. Inc. then appealed the decision with the Supreme Court, alleging
that the CA erred in its decision due to the following points:

- The petitioner should not have been made liable for the payment of wage differentials to the
22 individuals, as they themselves admitted in their affidavits that they were employees of
Pamplona Plantation Leisure Corp.
- The petitioner should not have been held liable for the illegal dismissal of Joselito Tinghil, as
Tinghil also stated in his own affidavit that he worked for Pamplona Plantation Leisure Corp.

- There was no evidence to support Tinghil's allegation that he was illegally dismissed.

- Pamplona Plantation Co. Inc. manager Jose Luis Bondoc should not have been held
personally liable for corporate acts.

In reexamining and reevaluating the evidence on record, the high tribunal upheld the CA
decision, but with modification. The SC decision absolved Bondoc of any personal liability as
regards the money claims of the respondents.

Taking the SC decision point by point, there is a need to establish the nature of the
respondents' employment in Pamplona Plantation Co. Inc.

Article 280 of the Labor Code defines the difference between regular and casual employment.

"The provisions of written agreement to the contrary notwithstanding and regardless of the
oral agreement of the parties, an employment shall be deemed to be regular where the
employee has been engaged to perform activities which are usually necessary or desirable in
the usual business or trade of the employer, except where employment has been fixed for a
specific project or undertaking the completion or termination of which has been determined at
the time of the engagement of the employee or where the work or service to be performed is
seasonal in nature and the employment is for the duration of the season.

An employment shall be deemed to be casual if it is not covered by the preceding paragraph:

Provided, That any employee who has rendered at least one year of service, whether such
service is continuous or broken, shall be considered a regular employee with respect to the
activity in which he is employed and his employment shall continue while such activity

While there were originally 66 complainants against Pamplona Plantation Co. Inc., the award
of wage differentials was limited to only 22 individuals, implying that the CA found the other 44
to be not regular employees, but were working for the company under different
circumstances, perhaps as contract workers. This was supported by the company's
presentation of its payroll, which indicated that some of the complainants were not regular

As far as the company's claim that the complainants were working for Pamplona Plantation
Leisure Corp., the court found that the firm's payroll indicated otherwise. The court also found
that the two companies could be considered one and the same, by the concept of piercing the
corporate veil.2

"An examination of the facts reveals that, for both the coconut plantation and the golf course,
there is only one management which the laborers deal with regarding their work. A portion of
the plantation (also called Hacienda Pamplona) had actually been converted into a golf
1 Labor Code of the Philippines (2008). pp. 152-153. World Class Printing and Publishing. Valenzuela City, Philippines.
2 Pamplona Plantation Co. Inc. vs. Ramon Acosta, et al. G.R. No. 153193. (2006) PHSC 1157 (Dec. 6, 2006). p. 6.
course and other recreational facilities. The weekly payrolls issued by petitioner-company
bore the name "Pamplona Plantation Co. Inc.." It is also a fact that respondents all received
their pay from the same person, Petitioner Bondoc -- the managing director of the company.
Since the workers were working for a firm known as Pamplona Plantation Co. Inc., the reason
they sued their employers through that name was natural and understandable.

True, the Petitioner Pamplona Plantation Co. Inc., and the Pamplona Plantation Leisure Corp.
appear to be separate corporate entities. But it is settled that this fiction of law cannot be
invoked to further an end subversive of justice."3

In Concept Builders Inc. vs. NLRC, the SC laid down the criteria whereby the "corporate veil"
may be pierced.

"The corporate mask may be lifted and the corporate veil may be pierced when a corporation
is just but the alter ego of a person or of another corporation. Where badges of fraud exist;
where public convenience is defeated; where a wrong is sought to be justified thereby, the
corporate fiction or the notion of legal entity should come to naught. The law in these
instances will regard the corporation as a mere association of persons and, in case of two
corporations, merge them into one.

Thus, where a sister corporation is used as a shield to evade a corporation’s subsidiary

liability for damages, the corporation may not be heard to say that it has a personality
separate and distinct from the other corporation. The piercing of the corporate veil comes into


It is a fundamental principle of corporation law that a corporation is an entity separate and

distinct from its stockholders and from other corporations to which it may be connected. But,
this separate and distinct personality of a corporation is merely a fiction created by law for
convenience and to promote justice. So, when the notion of separate juridical personality is
used to defeat public convenience, justify wrong, protect fraud or defend crime, or is used as
a device to defeat the labor laws, this separate personality of the corporation may be
disregarded or the veil of corporate fiction pierced. This is true likewise when the corporation
is merely an adjunct, a business conduit or an alter ego of another corporation.

The conditions under which the juridical entity may be disregarded vary according to the
peculiar facts and circumstances of each case. No hard and fast rule can be accurately laid
down, but certainly, there are some probative factors of identity that will justify the application
of the doctrine of piercing the corporate veil, to wit:

1. Stock ownership by one or common ownership of both corporations.

2. Entity of directors and officers.
3. The manner of keeping corporate books and records.
4. Methods of conducting the business."4

3 Ibid. p. 6.
4 Concept Builders Inc. vs. NLRC. G.R. No. 108734. May 29, 1996. Accessed Feb. 28, 2010.
In the instant case, the SC noted why the Petitioner could not invoke Pamplona Plantation
Leisure Corp.'s separate corporate identity as a defense.

"In the present case, the corporations have basically the same incorporators and directors
and are headed by the same official. Both use only one office and one payroll and are under
one management. In their individual Affidavits, respondents allege that they worked under the
supervision and control of Petitioner Bondoc -- the common managing director of both the
petitioner-company and the leisure corporation. Some of the laborers of the plantation also
work in the golf course. Thus, the attempt to make the two corporations appear as two
separate entities, insofar as the workers are concerned, should be viewed as a devious
but obvious means to defeat the ends of the law. Such a ploy should not be permitted
to cloud the truth and perpetrate an injustice."5

The high court likewise noted that the Petitioner focused on the nature of the respondents'
employment and did not use separate corporate identity as a defense, until after the NLRC's
ruling. And while some respondents identified Pamplona Plantation Leisure Corp. as their
employer, it was stated in their affidavits that both the leisure corporation and the petitioner-
company were engaged in the development and operation of sugar and coconut plantations,
as well as a golf course.

"These allegations reveals that petitioner successfully confused the workers as to who their
true employer was. All things considered, their faulty belief that the plantation company and
the leisure corporation were one and the same can be attributed solely to petitioners. It would
certainly be unjust to prejudice the claims of the workers because of the misleading actions of
their employer."6

On the issue of the illegal dismissal of Joselito Tinghil, the high court found sufficient basis to
affirm the appellate court's decision on the matter.

According to case facts, Tinghil stated in his Oct. 9, 1997 affidavit that on May 3, 1997, project
manager Lito Bundok (spelled Bondoc in some other parts of the records) called him and
other union officers and company employees to express "disgust" with their union activities.
They were then told not to report to work anymore. Instead of countering Tinghil's allegations,
the petitioner merely said Tinghil's narration in his affidavit was vague.

"It is well-settled that the employer has the burden of proving that the dismissal was for a valid
and just cause. Failure to discharge this burden of proof substantially means that the
dismissal was not justified and, therefore, illegal. Given petitioner's failure to discharge this
burden, the Court sustains the finding of illegal dismissal vis-a-vis respondent Joselito

Article 279, or the security of tenure provision, of the Labor Code states:

"In cases of regular employment, the employer shall not terminate the services of an
employee except for a just cause or when authorized by this Title. An employee who is
unjustly dismissed from work shall be entitled to reinstatement without loss of seniority rights
5 Pamplona Plantation Co. Inc. vs. Ramon Acosta et al. p.7.
6 Ibid. p. 8.
7 Ibid. pp. 8-9.
and other privileges and to his full backwages, inclusive of allowances, and to his other
benefits or their monetary equivalent computed from the time his compensation was withheld
from him up to the time of his actual reinstatement."8

The Labor Code, in Article 282, likewise outlines the criteria by which an employee may be
terminated from his job.

"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 representative in connection with his work;

b. Gross and habitual neglect by the employee of his duties;

c. Fraud or willful breach by the employee of the trust reposed in him by his employer or duly
authorized representative;

d. Commission of a crime or offense by the employee against the person of his employer or
any immediate member of his family or his duly authorized representatives; and

e. Other causes analogous to the foregoing."9

The Rules to Implement the Labor Code also specifies the need to serve proper notice to an
employee who is about to be terminated, as well as to give the benefit of due process to such
an employee.

"Rule XIV Section 2. Notice of dismissal. -- Any employer who seeks to dismiss a worker shall
furnish him a written notice stating the particular acts or omission constituting the grounds for
his dismissal. In cases of abandonment of work, the notice shall be served at the worker's last
known address.

Rule XIV Section 5. Answer and hearing. -- The worker may answer the allegations stated
against him in the notice of dismissal within a reasonable period from receipt of such notice.
The employer shall afford the worker ample opportunity to be heard and to defend himself
with the assistance of his representative, if he so desires.

Rule XIV Section 6. Decision to dismiss. -- The employer shall immediately notify a worker in
writing of a decision to dismiss him stating clearly the reasons therefor."

As was presented in the facts of the case, Tinghil was neither given a formal notice of
dismissal nor a chance to defend himself before his employer. He likewise was not told
exactly why he was being dismissed. Bondoc just told him not to report for work anymore.

On the issue of Bondoc's liability, the court ruled that he should not be held solidarily liable
with the company for the wage differentials awarded to the respondents. The decision was
based on Section 31 of the Corporation Code of the Philippines, which states:

8 Labor Code. p. 152.

9 Ibid. p. 153.
"Liability of directors, trustees or officers. -- Directors or trustees who willfully and knowingly
vote for or assent to patently unlawful acts of the corporation or who are guilty of gross
negligence or bad faith in directing the affairs of the corporation or acquire any personal or
pecuniary interest in conflict with their duty as such directors or trustees shall be liable jointly
and severally for all damages resulting therefrom suffered by the corporation, its stockholders
or members and other persons.

When a director, trustee or officer attempts to acquire or acquires, in violation of his duty, any
interest adverse to the corporation in respect of any matter which has been reposed in him in
confidence, as to which equity imposes a disability upon him to deal in his own behalf, he
shall be liable as a trustee for the corporation and must account for the profits which
otherwise would have accrued to the corporation."10

Corporate officers are defined in Section 25 of the Corporation Code to include "a president,
who shall be a director, a treasurer who may or may not be a director, a secretary who shall
be a resident and citizen of the Philippines, and such other officers as may be provided for in
the by-laws."11 This particular provision provides corporations enough leeway to appoint a
wide range of other officers to see to day-to-day operations and management. Such officers
could include vice presidents, cashiers, auditors, and general managers. Taking this
provision, it can be said that Bondoc is an officer of Pamplona Plantation Co. Inc.

On his liability to the respondents, it was stated in Midas Touch vs. NLRC that "a corporate
officer is not personally liable for the money claims of discharged corporate employees unless
he acted with evident malice and bad faith in terminating their employment."12

"In this case, there is no basis from which it may be deduced that Bondoc, as manager of
petitioner, is also a corporate officer such that he may be held liable for the money claims
awarded in favor of respondents. Even assuming that he is a corporate officer, still, there is no
showing that he acted with evident malice and bad faith. Bondoc may have signed and
approved the payrolls; nevertheless, it does not follow that he had a direct hand in
determining the amount of respondents' corresponding salaries and other benefits. Bondoc,
therefore, should not have been held liable together with petitioner,"13 the SC ruled.

Alternative courses of action

We concur with the SC decision, except for its absolution of Bondoc from all personal liability.

Nicario vs. NLRC states:

"The general rule is that officers of a corporation are not personally liable for their official acts
unless it is shown that they have exceeded their authority. However, the legal fiction that a
corporation has a personality separate and distinct from stockholders and members may be
disregarded if it is used as a means to perpetuate fraud or an illegal act or as a vehicle for the
evasion of an existing obligation, the circumvention of statutes, or to confuse legitimate

10 Corporation Code of the Philippines. Accessed Feb. 28, 2010.

11 Ibid.
12 Midas Touch Food Corp. vs. NLRC. G.R. No. 111639. July 29, 1996. Accessed Feb. 27, 2010.
13 Pamplona Plantation vs. Acosta et al.
issues."14 (Emphasis supplied)

Reiterating Midas Touch vs. NLRC:

"A corporate officer is not personally liable for the money claims of discharged corporate
employees unless he acted with evident malice and bad faith in terminating their
employment."15 (Emphasis supplied)

According to the records of the instant case, "Tinghil...together with other union officers and
company employees, were called personally by the project manager, Lito Bundok (spelled as
Bondoc in other parts of the records), who expressed his 'disgust' with their union activities.
They were then informed that they will not be allowed to report for work anymore."16

Bondoc's attitude toward Tinghil, a union officer, and his fellow union officers and other
company employees can be construed as an act of bad faith.

According to Gerald and Kathleen Hill, authors of The People's Law Dictionary and the Real
Life Dictionary of the Law, bad faith is defined as an "intentional dishonest act by not fulfilling
legal or contractual obligations, misleading another, entering into an agreement without the
intention or means to fulfill it, or violating basic standards of honesty in dealing with others."17

The employee-employer relationship that existed between Tinghil, et al. and Pamplona
Plantation Co. Inc. represented a contract of labor.

Section 2 Articles 1700 and 1701 of the Civil Code of the Philippines state:

"Art. 1700. The relations between capital and labor are not merely contractual. They are so
impressed with public interest that labor contracts must yield to the common good. Therefore,
such contracts are subject to the special laws on labor unions, collective bargaining, strikes
and lockouts, closed shop, wages, working conditions, hours of labor and similar subjects.

Art. 1701. Neither capital nor labor shall act oppressively against the other, or impair the
interest or convenience of the public."18

By dismissing Tinghil and some other union officers and employees without due process,
Bondoc acted oppressively against the dismissed workers, thus committing a violation of the
contract of labor. In the same light, his action could be taken as an act of bad faith as he
discriminated against Tinghil and the other employees' union leadership and membership, as
implied by the timing of his expression of disgust and the termination of the workers.

It was clearly stated in case records that Bondoc expressed "disgust" over Tinghil and the
others' union activities. The abrupt termination of their employment almost in the same vein
can be seen as an act tantamount to union busting.

14 Emelita Nicario vs. NLRC, et al. G.R. No. 125340. Sept. 17, 1998. Accessed Feb. 28, 2010.
15 Midas Touch vs. NLRC.
16 Pamplona Plantation vs. Acosta et al.
17 The Free Dictionary. Accessed Feb. 27, 2010.
18 Civil Code of the Philippines (2008). p. 261. ConvergeLink Books Corp. Legazpi City, Philippines.
The Constitution of the Republic of the Philippines, under Section 8 of the Bill of Rights,
explicitly states the inherent right of the people to self-organization:

"The right of the people, including those employed in the public and private sector, to form
unions, associations or societies for purposes not contrary to law shall not be abridged."19

The Labor Code expounds on this right.

"Art. 243. Coverage and employees' right to self-organization. All persons employed in
commercial, industrial and agricultural enterprises and in religious, charitable, medical, or
educational institutions, whether operating for profit or not, shall have the right to self-
organization and to form, join, or assist labor organizations of their own choosing for purposes
of collective bargaining. Ambulant, intermittent and itinerant workers, self-employed people,
rural workers and those without any definite employers may form labor organizations for their
mutual aid and protection.

Art. 246. Non-abridgment of right to self-organization. It shall be unlawful for any person to
restrain, coerce, discriminate against or unduly interfere with employees and workers in their
exercise of the right to self-organization. Such right shall include the right to form, join, or
assist labor organizations for the purpose of collective bargaining through representatives of
their own choosing and to engage in lawful concerted activities for the same purpose for their
mutual aid and protection, subject to the provisions of Article 264 of this Code."20

Taking these provisions into action, the Philippine Daily Inquirer Employees' Union, the
strongest union in Philippine media, included these in its July 11, 2007 to July 10, 2010
collective bargaining agreement with Philippine Daily Inquirer Inc.

"The company shall not interfere with, restrain, coerce, discharge or discriminate against any
of its employees because of membership in the union, service in the Grievance Committee, or
any legitimate union activity; provided, that no union activity shall be so transacted during
company time (except those connected with cases before the Grievance Committee or Labor-
Management Committee) as to interrupt with the normal and regular operations of the

While there was no excerpt of the Pamplona Plantation Co. Inc. employees' union's CBA in
the court records that would show an agreement between company and union to allow union
activities, the existence of laws protecting the right to self-organization -- embodied by the
Constitution itself -- showed that Bondoc committed a violation of workers' rights.

Also in effect, Bondoc, by his mere act, could be cosidered guilty of unfair labor practices, as
defined by the Labor Code.

"Art. 247. Concept of unfair labor practice and procedure for prosecution thereof. Unfair labor
practices violate the constitutional right of workers and employees to self-organization, are
19 Nolledo, Jose N. The Constitution of the Republic of the Philippines. (1986). p. 5. Philippine Graphic Arts Inc. Caloocan
City, Philippines.
20 Labor Code. pp. 125-126.
21 Philippine Daily Inquirer Employees' Union Collective Bargaining Agreement, July 11, 2007 to July 10, 2010.
inimical to the legitimate interests of both labor and management, including their right to
bargain collectively and otherwise deal with each other in an atmosphere of freedom and
mutual respect, disrupt industrial peace and hinder the promotion of healthy and stable labor-
management relations. (Emphasis supplied)

Consequently, unfair labor practices are not only violations of the civil rights of both labor and
management but are also criminal offenses against the State which shall be subject to
prosecution and punishment as herein provided.


Art. 248. Unfair labor practices of employers. It shall be unlawful for an employer to commit
any of the following unfair labor practice:

a. To interfere with, restrain or coerce employees in the exercise of their right to self-

b. To require as a condition of employment that a person or an employee shall not join a labor
organization or shall withdraw from one which he belongs.


The provisions of the preceding paragraph notwithstanding, only the officers and agents of
corporations, associations or partnerships who have actually participated in, authorized or
ratified unfair labor practices shall be held criminally liable."22

While there was no explicit mention of Bondoc interfering with, restraining, or coercing
employees of their right to self-organization, an effective violation of the law, the timing of his
talk with Tinghil and the other union officers and his termination of them is suspect. The
dismissal of Tinghil, et al. came at the heels of Bondoc's expression of disgust over their
union activities.

In Maglutac vs. NLRC, the court took cognizance of the timing of the firing of petitioner Jose
Maglutac in relation with his parents' filing of a derivative suit against respondents -- the
company he is working for and its president.

"After studying in depth the facts and the evidence it is difficult to divert from the fact that the
dismissal of complainant was triggered by his parent’s filing a derivative suit against
respondents with the Securities and Exchange Commission where it is alleged that the
company’s president and his wife siphoned company funds to their private bank accounts.
Complainant’s cause of termination cannot easily and simply be detached from the filing of
the minority stockholders’ derivative suit as this dismissal came abruptly shortly after the
derivative suit was filed. Complainant’s brother who was likewise employed by respondents
was likewise dismissed and this came on the heels of the suit filed with the Securities and
Exchange Commission.

The sequence of events should not be overlooked. It provides the link for the dismissal of

22 Labor Code. pp. 126-129.

complainant and his brother."23 (Emphasis supplied)

In the instant case, Bondoc personally called Tinghil and other union officers and company
employees to express his "disgust" over their union activities, and then fired them immediately
thereafter -- providing an implicit link between their union activities and the employees'

According to Article 32 of the Civil Code:

"Any public officer or employee, or any private individual, who directly or indirectly obstructs,
defeats, violates or in any manner impedes or impairs any of the following rights and liberties
of another person shall be liable to the latter for damages:


(12) The right to become a member of associations or societies for purposes not contrary to


In any of the cases referred to in this article, whether or not the defendant's act or omission
constitutes a criminal offense, the aggrieved party has a right to commence an entirely
separate and distinct civil action for damages, and for other relief. Such civil action shall
proceed independently of any criminal prosecution (if the latter be instituted), and may be
proved by a preponderance of evidence.

The indemnity shall include moral damages. Exemplary damages may also be adjudicated.

The responsibility herein set forth is not demandable from a judge unless his act or omission
constitutes a violation of the Penal Code or other penal statute."24

Violations of various provisions of the Civil Code can be cause for claims of moral damages.

"Art. 2217. Moral damages include physical suffering, mental anguish, fright, serious anxiety,
besmirched reputation, wounded feelings, moral shock, social humiliation, and similar injury.
Though incapable of pecuniary computation, moral damages may be recovered if they are the
proximate result of the defendant's wrongful act for omission.

Art. 2219. Moral damages may be recovered in the following analogous cases:


23 Jose Maglutac vs. NLRC et al. G.R. No. 78345. Sept. 21, 1990.
+nlrc&hl=tl&gl=ph&sig=AHIEtbSvtE8eBz4ogu5uGahIAaHBApmgFA&pli=1. Accessed Feb. 27, 2010.
24 Civil Code. pp. 5-7.
(10) Acts and actions referred to in Articles 21, 26, 27, 28, 29, 30, 32, 34 and 35."25

Conclusion and recommendation

Considering the chain of events and the applicable laws, we find that Jose Luis Bondoc
should be held jointly and severally liable with Pamplona Plantation Co. Inc. for the illegal
dismissal of Joselito Tinghil. His acts can be considered tantamount to union busting, and he
cannot invoke the principle of a corporate officer being merely an agent of the corporation,
and so should be absolved of any personal liability.

It was one thing to express his "disgust" over Tinghil, et al.'s union activities. It was another
thing to fire them immediately after. As noted in the Supreme Court ruling on Maglutac vs.
NLRC, timing should also be considered.

Although, as project manager, Bondoc can claim that he merely acted on behalf of
management in terminating Tinghil et al., the "disgust" that he showed, particularly in relation
to the dismissed employees' union activities, was ill-placed. He may not be pleased with the
employees' union activities, but the least he could do was hide it -- especially if, when he
called the concerned employees, he had the express intention of terminating them.

In our opinion, Bondoc should have been more careful with the way he treated the
employees, considering that he expressed his disgust with the employees' union activities,
immediately prior to their termination without proper notice and due process. It could be seen
as a form of threat to other employees who are union members that the same can also
happen to them.

The Philippine Constitution itself protects the rights of individuals to join or form unions, as
long as such organizations do not run counter to existing laws. Management will do well to
remember that labor unions are recognized and supported by law. Members of management
should take more care in dealing with its employees, regardless of whether they are union
officers, union members, or even non-union members. In an employee-employer relationship,
there should be mutual respect. If an employer finds something wrong with an employee and
would like to fire him, due process should be exercised. In the same light, employees should
express their dissatisfaction with management in appropriate ways and through proper
channels. This way, disputes may be avoided.


25 Ibid. p. 365.