St. Luke’s Med. Center Inc. v. Sanchez

Doctrine: The right of an employer to regulate all aspects of employment, aptly called “management prerogative,” gives employers the freedom to regulate, according to their discretion and best judgment, all aspects of employment, including work assignment, working methods, processes to be followed, working regulations, transfer of employees, work supervision, lay-off of workers and the discipline, dismissal and recall of workers.

FACTS:

Sanchez is a nurse at St. Luke’s Medical Center, Inc. (SLMC) until her termination on July 6, 2011 for her purported violation of SLMC’s Code of Discipline, particularly Section 1, Rule 1 on Acts of Dishonesty, i.e., Robbery, Theft, Pilferage, and Misappropriation of Funds.

At the end of her shift on May 29, 2011, Sanchez passed through the SLMC Centralization Entrance/Exit where she was subjected to the standard inspection procedure by the security personnel.  In the course thereof, the Security Guard on-duty, Jaime Manzanade  (SG Manzanade), noticed a pouch in her bag and asked her to open the same. When opened, said pouch contained assortment of medical stocks which were subsequently confiscated.

She was directed to write an Incident Report explaining why she had the questioned items in her possession. She complied with the directive and also submitted an undated handwritten letter of apology. Consequently, Sanchez was placed under preventive suspension.

In her position paper, Sanchez maintained her innocence, claiming that she had no intention of bringing outside the SLMC’s premises the questioned items since she merely inadvertently left the pouch containing them in her bag as she got caught up in work that day. She further asserted that she could not be found guilty of pilferage since the questioned items found in her possession were neither SLMC’s nor its employees’ property. She also stressed the fact that SLMC did not file any criminal charges against her. Anent her supposed admission in her handwritten letter, she claimed that she was unassisted by counsel when she executed the same and, thus, was inadmissible for being unconstitutional.

LA: Sanchez was validly dismissed.  Act of dishonesty as provided for under SLMC’s Code of discipline.

NLRC; Reversed; Sanchez was illegally dismissed. Unique case, considering that keeping excess hospital stocks or “hoarding” was an admitted practice amongst nurses in the Pediatric Unit which had been tolerated by SLMC management for a long time.

CA: Upheld ruling of NLRC. It ruled that Sanchez’s offense did not qualify as serious misconduct.

ISSUE:

WON Sanchez was illegally dismissed.

HELD:

NO. The right of an employer to regulate all aspects of employment, aptly called “management prerogative,” gives employers the freedom to regulate, according to their discretion and best judgment, all aspects of employment, including work assignment, working methods, processes to be followed, working regulations, transfer of employees, work supervision, lay-off of workers and the discipline, dismissal and recall of workers. In this light, courts often decline to interfere in legitimate business decisions of employers.  In fact, labor laws discourage interference in employers’ judgment concerning the conduct of their business.

Among the employer’s management prerogatives is the right to prescribe reasonable rules and regulations necessary or proper for the conduct of its business or concern, to provide certain disciplinary measures to implement said rules and to assure that the same would be complied with. At the same time, the employee has the corollary duty to obey all reasonable rules, orders, and instructions of the employer; and willful or intentional disobedience thereto, as a general rule, justifies termination of the contract of service and the dismissal of the employee.  (Article 296 of the Labor Code.)

Note that for an employee to be validly dismissed on this ground, the employer’s orders, regulations, or instructions must be: (1) reasonable and lawful, (2) sufficiently known to the employee, and (3) in connection with the duties which the employee has been engaged to discharge.”

The Court finds that Sanchez was validly dismissed by SLMC for her willful disregard and disobedience of Section 1, Rule I of the SLMC Code of Discipline, which reasonably punishes acts of dishonesty, i.e., “theft, pilferage of hospital or co-employee property, x x x or its attempt in any form or manner from the hospital, co-employees, doctors, visitors, [and] customers (external and internal)” with termination from employment. Such act is obviously connected with Sanchez’s work, who, as a staff nurse, is tasked with the proper stewardship of medical supplies. Significantly, records show that Sanchez made a categorical admission in her handwritten letter that despite her knowledge of its express prohibition under the SLMC Code of Discipline, she still knowingly brought out the subject medical items with her.

As it stands, the Court thus holds that the dismissal of Sanchez was for a just cause, supported by substantial evidence, and is therefore in order. By declaring otherwise, bereft of any substantial bases, the NLRC issued a patently and grossly erroneous ruling tantamount to grave abuse of discretion, which, in turn, means that the CA erred when it affirmed the same. In consequence, the grant of the present petition is warranted.

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