Manila Electric Company v. National Labor Relations Commission | Narvasa, J.

FACTS Meralco employees discovered that Antonio Sanchez was

consuming electricity through an illicit connection (shunt) to a Meralco service line, which was said to have been connected by Jose Masaya, a Meralco employee.

The Meralco Legal Department sent Jose Masaya a letter charging Masaya with a violation of the Company Code on Employee Discipline, and conducted a formal investigation.

Prior to being interrogates, Masaya stated that he did not need a lawyer because "ang sasabihin ko naman dito ay pawang katotohanan lamang"

o Masaya diposed that he installed the connection, and that he received P200 from Antonio Sanchez for the service.

o Masaya sought forgiveness for the offense: Nais ko po sanang ihingi ng kapatawaran sa kumpanya ang mga nagawa kong pagkakamali. Anim po ang aking mga anak...Kayat ipinakikiusap ko sa inyo na ipaabot ninyo sa kompanya ang aking pagmamakaawa.

Meralco filed with the Ministry of Labor and Employment an application for clearance to terminate Masaya's services, and served a copy on the latter.

o Masaya was also placed Masaya under preventive suspension.

Masaya filed a complaint for illegal dismissal against Meralco. LA ruled in favor of Masaya.

o The investigation conducted by Meralco should not be accorded credence;

o Masaya was a bill collector, not a lineman collector, hence, he does not know how to install electrical connection;

o The money received by Masaya from Sanchez was representation expenses in following up Mr. Sanchez' application for installation of electric facilities.

NLRC affirmed the Arbiter's decisiono Although only substantial evidence is required in

administrative proceedings, the instant case is an exception as Masaya is being charged with a criminal offense, therefore, it is incumbent upon the Meralco to prove beyond reasonable doubt the existence of the crime.

ISSUEWoN the NLRC was correct in upholding the Labor Arbiter in ruling that Meralco illegally dismissed Masaya.—NO. Masaya was NOT illegally dismissed.

Implicit concession: under the substantial evidence rule, the evidence would be adequate to make out a case of gross misconduct on the part of Masaya

HOWEVER, NLRC’s theory is that the judgment against Masya was precluded by the doctrine of proof beyond reasonable doubt.

o Since there is no causal connection between private respondent's duties to the crime imputed to him, mere substantial evidence is insufficient to hold Masaya guilty of installing electrical connection.

RATIO In administrative or quasi-judicial proceedings, proof beyond

reasonable doubt is NOT required as basis for a judgment of the legality of an employer's dismissal of an employee, nor even preponderance of evidence, substantial evidence being sufficient.

o The rules of evidence are NOT controlling.o it is the spirit and intention of the Labor Code that the

Commission and the Labor Arbiters shall use every and all reasonable means to ascertain the facts in each case speedily and objectively and without regard to the technicalities of law or procedure, in the interest of due process.

The ground for an employer's dismissal of an employee need be established only by substantial evidence.

o It is absolutely of no consequence that the misconduct with which an employee may be charged also constitutes a criminal offense.

o The proceedings being administrative, the quantum of proof is governed by the substantial evidence rule, NOT by the rule governing judgments in criminal actions.

The following facts of record constitute sufficient evidence to prove the commission by Masaya of an act of dishonesty:

o The reality of the illegal electrical connection;o The written communication to Masaya, accusing him of

the illegal connection and the notice of formal investigation thereon;

o Masaya's acknowledgment of the same ans his declining to be assisted by counsel;

o Masya’s voluntary admission that it was he who had made the illegal electrical connection, describing the manner by which he had made it, and that he had received P250.00 from Antonio Sanchez; and

o Masaya’s plea to the company for forgiveness.o Testimony of Sanchez’s servants identifying Masaya.o There is nothing in the record to demonstrate that

Masaya's admissions were made otherwise than voluntarily;

his assertion that he had been "starved" into signing the admissions is not persuasive, and was not accepted by the Arbiter or the Commission.