Case Digest: Integrated Microelectronics v. Pionilla

G.R. No. 200222 : August 28, 2013




Pionilla was hired by IMI as its production worker. Pionilla received a notice from IMI requiring him to explain the incident which occurred the day before where he was seen escorting a lady to board the company shuttle bus at the Alabang Terminal. It was reported by the bus marshall that the lady was wearing a company identification card (ID) which serves as a free pass for shuttle bus passengers even if she was just a job applicant at IMI. In this regard, Pionilla admitted that he lent his ID to the lady who turned out to be his relative. He further intimated that he risked lending her his ID to save on their transportation expenses. Nevertheless, he apologized for his actions.

IMI found Pionilla guilty of violating Article 6.12 of the Company Rules and Regulations (CRR) which prohibits the lending of ones ID since the same is considered a breach of its security rules and carries the penalty of dismissal. Subsequently, Pionilla received a letter dated August 16, 2005 informing him of his dismissal from service. Three days after, he filed a complaint for illegal dismissal with damages against IMI.

LA ruled that Pionilla has been illegally dismissed. On appeal, the NLRC reversed the LAs ruling, finding Pionillas dismissal to be valid. It pointed out that Pionillas act of lending his temporary ID was willful and intentional. Dissatisfied, Pionilla filed a petition for certiorari before the CA. The CA rendered a Decisiongranting Pionillas petition. It found that while IMIs regulations on company IDs were reasonable, the penalty of dismissal was too harsh and not commensurate to the misdeed committed. In view of the CAs ruling, IMI filed a petition for review on certiorari before the Supreme Court but the same was denied. Hence, motion for reconsideration was filed.

ISSUE: Whether or not Pionilla may be entitled to full backwages

HELD: No. Full backwages are deleted.

Labor Law
As a general rule, an illegally dismissed employee is entitled to reinstatement (or separation pay, if reinstatement is not viable) and payment of full backwages. In certain cases, however, the Court has carved out an exception to the foregoing rule and thereby ordered the reinstatement of the employee without backwages on account of the following : (a) the fact that dismissal of the employee would be too harsh of a penalty; and (b) that the employer was in good faith in terminating the employee.

The Court is convinced that petitioner's guilt was substantially established. Nevertheless, we agree with respondent Minister's order of reinstating petitioner without backwages instead of dismissal which may be too drastic. Denial of backwages would sufficiently penalize her for her infractions. The bank officials acted in good faith. They should be exempt from the burden of paying backwages. The good faith of the employer, when clear under the circumstances, may preclude or diminish recovery of backwages. Only employees discriminately dismissed are entitled to backpay.