### Facts
In December 1992 and January 1993, Cosmos Bottling Corporation discovered that unremitted sales proceeds amounting to P130,000 were missing from its San Pedro Plant. Personnel Manager Leonardo Makasili and Comptroller Manuel Lim led an investigation, which targeted seven salesmen and three checkers as potential culprits: Sergio C. Rey, Sixto Batino, Rizalino T. Tamondong, Roberto Santos, Herminio G. Dela Cruz, Emilio B. Magleo, Johnny G. Bacani, Zaldy G. Guzman, Jonathan Y. Relevo, and Ireneo Solis. The employees denied their involvement and blamed the guards. Despite their denials, Cosmos terminated them on grounds of “fraudulent conspiracy” and dishonesty, primarily relying on the testimony of Saturnino Montecalvo.
The respondents filed a complaint for illegal dismissal with the Labor Arbiter (NLRC NCR Case No. 02-00968-93), seeking reinstatement and backwages. On December 27, 1996, the Labor Arbiter ruled in favor of the respondents, finding their dismissal illegal and awarding them separation pay and backwages totaling P1,491,517.75.
### Procedural Posture
1. Cosmos appealed to the NLRC, which modified the Arbiter’s Decision only to recompute Guzman’s separation pay based on 13 years of service.
2. Cosmos filed for reconsideration with the NLRC, which was denied on May 17, 1999.
3. On July 5, 1999, Cosmos filed a petition for certiorari with the Court of Appeals, alleging NLRC’s grave abuse of discretion.
4. On August 4, 2000, the Court of Appeals dismissed the petition and affirmed the NLRC’s Resolutions.
5. Cosmos filed a motion for reconsideration, which was denied on December 13, 2000.
6. Cosmos subsequently filed a petition for review on certiorari with the Supreme Court.
### Issues
1. Whether the Court of Appeals erred by affirming the NLRC’s decision that upheld the illegal dismissal findings of the Labor Arbiter.
2. Whether the case involves questions of fact, rendering it beyond the Supreme Court’s jurisdiction under Rule 45 of the 1997 Rules of Civil Procedure.
### Court’s Decision
The Supreme Court denied the petition, affirming the Court of Appeals’ decision.
1. **Legality of Dismissal**:
– The Court reiterated that employers have the burden of proving valid cause for termination.
– The Labor Arbiter and NLRC found that Cosmos failed to establish the individual culpability of each respondent by substantial evidence.
– The Court of Appeals supported this finding, noting no grave abuse of discretion.
2. **Jurisdiction under Rule 45**:
– The Court emphasized that petitions under Rule 45 should raise questions of law, not fact.
– Cosmos’s primary issue was factual—relating to the assessment of evidence regarding the alleged participation in dishonesty and conspiracy.
– The factual findings by the Labor Arbiter, affirmed by NLRC, and supported by the Court of Appeals, were thus beyond the Supreme Court’s review since none of the exceptions (lack of evidence or misapprehension of facts) applied.
### Doctrine
1. **Burden of Proof in Dismissal Cases**: Employers must substantiate claims of valid cause with substantial evidence, especially in accusations like fraud and conspiracy.
2. **Review Limitations under Rule 45**: The Supreme Court in a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure is limited to reviewing legal errors, not factual ones.
### Class Notes
– **Burden of Proof**: In dismissal cases, this is on the employer to establish valid reasons for termination.
– **Substantial Evidence**: The threshold of proof required in labor cases, equating to such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.
– **Finality of Factual Findings**: Findings of fact by the NLRC, especially when affirmed by the Court of Appeals, are generally conclusive when supported by substantial evidence.
Key Statute:
– **Rule 45 of the 1997 Rules of Civil Procedure**: Limits review to questions of law, exempts factual assessment unless findings lack substantial evidence or are based on a misapprehension of facts.
### Historical Background
During the 1990s, employment disputes in the Philippines frequently revolved around the standards for lawful termination and the procedural rights of employees. Judicial approaches like the one in this case underscored the protection awarded to employees against dismissal without substantive justification, reflecting broader labor rights trends globally aiming to balance employer power with employee security.
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