Nanolan v. Agrinanas Dev (G.R. No. 240075. August 20, 2018)

CASE DIGEST: G.R. No. 240075, August 20, 2018. EDGAR T. NANOLAN V. AGRINANAS DEV. COMPANY, INC. AND/OR FRANCUCCI O. RABANES (HR MANAGER) AND MS. ROSSANA C. CALINGIN (HR DIRECTOR). G.R. No. 240075 - Edgar T. Nanolan v. Agrinanas Dev. Company, Inc. and/or Francucci O. Rabanes (HR Manager) and Ms. Rossana C. Calingin (HR Director).

FACTS: Petitioner was convicted of murder. The Labor Arbiter, the NLRC and the CA found that petitioner was validly dismissed on the ground of conviction for a crime involving moral turpitude, which warranted the penalty of dismissal pursuant to respondent Agrinanas Development Company, Inc.'s Employee Discipline System.

ISSUE: Petitioner now wants the Supreme Court to look into whether his conviction involved moral turpitude and, hence, can be the valid basis or ground for his dismissal. He also alleges unfair labor practice on the part of his employer.

HELD: As aptly ruled by the three tribunals, the circumstances of petitioner's case showed the presence of moral turpitude. In the case of International Rice Research Institute v. NLRC (IRRI case), the Court held that the issue of whether or not a particular conviction involved moral turpitude was a question of fact and depended on the surrounding circumstances.

Thus, in the IRRI case, the Court did not sustain the dismissal of an employee on the ground of conviction for homicide, holding that the crime committed did not involve moral turpitude taking into consideration the attendant mitigating circumstances of incomplete self-defense and voluntary surrender, plus total absence of any aggravating circumstance.

However, in the present case, petitioner's intent to kill and the degree of moral depravity was indeed clearly proven beyond reasonable doubt. The Court thus finds correct the factual finding and legal conclusion that petitioner was convicted of a crime involving moral turpitude. Besides, factual findings of administrative agencies that are affirmed by the CA are conclusive on the parties and not reviewable by this Court.

As to the charge of unfair labor practice, we likewise find no cogent reason to overturn the uniform findings of the labor tribunals that there was no sufficient allegation nor competent, clear and convincing evidence to prove that respondents violated the worker's right to self-organization.

[1] 293 Phil. 823, 834-835 (1993).
[2] Herida v. F & C Pawnshop and Jewelry Store/Florete, Jr., 603 Phil. 385, 390 (2009).