Case Digest: Chuanico v. Legacy Consolidated Plans

G.R. No. 181852 : OCTOBER 9, 2013




Legacy Plans Philippines, Inc. (Legacy Plans) hired petitioner Eric V. Chuanico (Atty. Chuanico) as Assistant Vice-President for Legal Services. He was to serve as in-house counsel for the company and its subsidiaries under the supervision of Atty. Christine A. Cruz (Atty. Cruz), the Senior Vice-President for Legal Affairs. Legacy Plans merged with Consolidated Plans Philippines, Inc. to become Legacy Consolidated Plans, Inc. (Legacy Consolidated).

October 17, 2002 Atty. Cruz wrote Atty. Chuanico a memorandum, requiring him to explain why no administrative action should be taken against him for mishandling two cases. In the first case he was supposed to draft an answer to a complaint for Bank of East Asia (a Legacy Consolidated affiliate) but he belatedly drafted a haphazard one that he gave to the handling lawyers without coursing it to his superior. In his defense, Atty. Chuanico said that he was given only one day within which to finish the draft. While admitting that his superior had no opportunity to review it for lack of time, he denied that the answer had been haphazardly done.

In the second case, Atty. Chuanico was required to prepare a complaint-affidavit for the Rural Bank of Paraque (also a Legacy Consolidated affiliate) against a certain De Rama but he failed to do so. Atty. Chuanico replied that the case had not actually been turned over to him. It was originally assigned to Atty. Dennis Amparo who later said that the complaint-affidavit could not be prepared because the Rural Bank had no witness.

On December 5, 2002, Legacy Consolidated dismissed Atty. Chuanico with effect on December 20, 2002 for serious misconduct, wilful disobedience to lawful orders, gross and habitual neglect of duties, and wilful breach of trust. Atty. Chuanico then filed a complaint for illegal dismissal.

The Labor Arbiter (LA) rendered a decision finding Legal Consolidated guilty of illegal dismissal. The National Labor Relations Commission (NLRC) affirmed LAs decision. The CA, however, held that the NLRC committed grave abuse of discretion.

ISSUE Whether or not Legacy Consolidated illegally dismissed Atty. Chuanico?

HELD: Atty. Chuanico was illegally dismissed.

LABOR LAW: illegal dismissal

To be a valid cause for dismissal, the loss of trust must be based on a wilful breach of such trust and founded clearly on established facts. The company charged him with having mishandled two things that were assigned to him, the drafting of an answer in one and the preparation of a complaint affidavit in the other. It failed to present proof, however, of such mishandling.

In CAPANELA v. National Labor Relations Commission, the court held that the factual findings of quasi-judicial bodies, which arc triers of facts on matters within their expertise, should be considered, when supported by substantial evidence, binding and conclusive on appellate courts. Here the LA and the NLRC were in better positions to assess and evaluate the credibility of the parties' claims and the weight to which their respective evidence is entitled.

Under Article 282(c) of the Labor Code, the breach of trust must be wilful. Ordinary breach will not be enough. A breach is willfull if it is done intentionally and knowingly without any justifiable excuse, as distinguished from an act done carelessly, thoughtlessly or inadvertently. Willfull breach was not proved in this case.

Petiton for review on certiorari is GRANTED. Decision of CA is SET ASIDE.