Ruffy v NLRC

GR No. 84193, February 15, 1990

Sarmiento, J.

Facts:

1. Diosdado Ruffy, petitioner, was employed with Central Azucarera Don Pedro. As an
employee, he was receiving an amount of Php37.31/day. He was assigned in the
Materials and Supply Section, Supply and Warehousing Department of the company.
Ruffy’s tasks were as follows:

a. to verify and check incoming materials and supplies

b. To issue requisitioned materials and supplies to authorized personnel of the
various departments.

2. On November 1984, Ruffy issued 25 sets of roller bearings covered by a Material Issue
Slip to a person who signed as Role. However, bearings were not received by the
requisitioning department concerned.
3. In view of the incident, an investigation was ensued. It was found that the bearings
released were sold to factoria de Nasugbu by Anastacio Maulleon Jr (also an employee
of Central Azucarera Don Pedro and was terminated because of involvement in the
incident). Alfredo Role was also investigated. Role denied alleged participation in the
incident. Ruffy could not recall if Role was the same person who received the bearings.
4. On December 1984, Ruffy was dismissed from service for breach of trust, gross
negligence, and flagrant inefficiency with forfeiture of all rights and privileges.
5. Ruffy filed the complaint with a Labor Arbiter. However, LA rendered decision that the
dismissal of petitioner was legal. That Central Azucarera Don Pedro “having
substantially complied with the law as envisioned under BP Blg 130”, need not to be
subject to the claims for damages of petitioner. Such request of petitioner was dismissed
due to lack of merits. However, respondent company is requested to give petitioner the
amount of P1, 119.30 in the form of financial assistance and that such order must be
rendered 15 days from receipt of decision.
6. Petitioner appealed to NLRC. NLRC affirmed decision of LA. Hence, petitioner filed a
special civil action for certiorari.

Issue/s:

WON the dismissal of petitioner is in conformity with the provisions BP Blg 130 and its IRR?

Ruling:

No. Petitioner was not given the “ample” opportunity” referred to in the labor relations law of
1981. The procedure prior to dismissal of an employee needs not to be observed to the letter,
but at least, it must be done in the natural sequence of notice, hearing, and judgment.

According to SC, “ample opportunity” is meant every kind of assistance that the management
must accord to the employee to enable him to prepare adequately his defense.
In the case at bar, the petitioner was informed that his services had been terminated. However,
respondent was not given the opportunity to defend himself as he had been fired by the
company.

SC stressed that the process set forth by the law need not be according to its letter but rather
according to spirit as a measure of due process. Likewise, it held that to fire an employee and
let him explain later is not in accord with the said expedient.

Hence, petition of Ruffy was granted. Private respondent ordered to reinstate petitioner with
back wages equivalent to 3 years without loss of seniority rights and other benefits, and without
deductions and qualifications.

Key points: just cause, ample opportunity based on labor relations law 1981, procedure of
dismissal.