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 decision
o
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.

ISSUE
WoN the NLRC was correct in upholding the Labor Arbiter in ruling

that Meralco illegally dismissed Masaya.NO. Masaya was NOT

illegally dismissed.

RATIO

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, NLRCs 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.
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
Masyas 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
o
o

Masayas plea to the company for forgiveness.

Testimony of Sanchezs servants identifying Masaya.
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.