#### Facts:
1. **Employment and Reassignments**: Rene Valiao was hired by West Negros College (WNC) on February 5, 1990, as the Student Affairs Office Director and subsequently took on various roles, including Acting Director, Alumni Affairs Office, and Records Chief, before becoming a typist due to complaints of tardiness and absences.
2. **Tardiness Reports and Suspensions**: Numerous reports were filed regarding Valiao’s persistent tardiness and absence from work. He was suspended for 15 days in January 1992 for dishonesty in reporting attendance and later faced further warnings and memoranda addressing his absenteeism and tardiness.
3. **Appeal to College President**: Valiao appealed to the new college president, who allowed him to continue working and even gave him a part-time teaching job to supplement his income. However, Valiao failed to immediately assume his new post.
4. **Criminal Involvement and Preventive Suspension**: On January 28, 1993, Valiao was arrested for alleged possession of marijuana following a police raid, leading WNC to suspend him preventively. Although Valiao requested due process, he was ultimately terminated after a committee investigation.
5. **Labor Complaint**: Valiao lodged a formal complaint against WNC for illegal suspension and dismissal. The Labor Arbiter ordered WNC to pay back salaries for the preventive suspension period and dismissed Valiao’s claims for illegal dismissal. Both the NLRC and the Court of Appeals upheld the Labor Arbiter’s decisions.
6. **Certiorari Petition in the Supreme Court**: Valiao challenged the Court of Appeals’ ruling in the Supreme Court, contending that his dismissal violated procedural and substantive due process.
#### Issues:
1. **Validity of Dismissal**: Whether Valiao’s dismissal based on serious misconduct and habitual neglect of duty, including frequent tardiness and absences, was justified.
2. **Due Process**: Whether Valiao was given proper notice and a fair hearing before his termination.
3. **Entitlement to Damages and Attorney’s Fees**: Whether Valiao is entitled to moral and exemplary damages and attorney’s fees due to alleged violations of his constitutional rights.
#### Court’s Decision:
1. **Validity of Dismissal**:
– **Just Causes**: The Supreme Court upheld Valiao’s dismissal, confirming it was justified by habitual absenteeism and tardiness, which constitute gross and habitual neglect of duty under the Labor Code. It emphasized that the infractions were neither isolated incidents nor mitigated by subsequent good conduct.
– **Evidence and Consistency**: The court noted that consistent reports and warnings about Valiao’s absences and tardiness substantiated his dismissal, and dismissed the notion that his arrest was the pivotal reason for his termination.
2. **Due Process**:
– **Procedural Compliance**: The Supreme Court found that due process was observed as WNC provided multiple notices to Valiao regarding his tardiness and the arrest incident. Furthermore, he was given opportunities to explain his side, and the investigation procedures were duly documented.
– **Opportunity to Defend**: Though dealing with personal and legal issues simultaneously, Valiao was still afforded the chance to be heard, fulfilling the essence of administrative due process.
3. **Damages and Attorney’s Fees**:
– **Lack of Basis for Damages**: The court denied Valiao’s claim for moral and exemplary damages, finding no evidence of ill faith or arbitrariness from WNC.
– **Attorney’s Fees**: The initial award of attorney’s fees was deleted as Valiao’s dismissal was valid.
#### Doctrine:
1. **Just Causes for Termination**: An employee’s repeated absences without leave and habitual tardiness signify gross and habitual neglect of duties, justifying termination. This principle emphasizes that the totality of infractions should be considered to understand the severity and habituality of misconduct.
2. **Due Process in Administrative Termination**: The requirement is for notice and an opportunity to be heard. A formal hearing is not mandatory; reasonable opportunities to explain and defend one’s self suffice.
3. **Management Prerogative**: Employers retain the prerogative to discipline employees, including dismissal for valid cause, provided that it is done in good faith, in line with legal standards, and with proper procedural safeguards.
#### Class Notes:
– **Just Causes for Termination**: Refer to Article 282 of the Labor Code – (a) serious misconduct, (b) habitual neglect of duties.
– **Due Process Requirements**: Dual notice and hearing or at least an opportunity to be heard.
– **Management Prerogative**: Should be exercised fairly and in line with labor laws.
– **Attorney’s Fees**: Awarded only if dismissal is found to be without just cause and involving bad faith.
#### Historical Background:
This case took place within the broader context of labor disputes and the administration of labor laws in the Philippines. The case is significant because it reiterates the principles surrounding valid grounds for dismissal and employer’s duty to observe due process. The decision highlights the balance between protecting employees’ rights and respecting employers’ management prerogatives within the established labor legal framework.
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