### Facts:
The case revolves around Jeffrey E. Santos, a company driver for Distribution & Control Products, Inc., who was dismissed from employment under suspicions of theft. Santos filed a complaint for constructive illegal dismissal and payment of separation pay on July 25, 2011, claiming he was unjustly suspended and subsequently barred from returning to work post-suspension. The company, led by Vincent M. Tiamsic, argued Santos was part of a theft of company products, which led to his preventive suspension and eventual job abandonment, a claim Santos denied.
### Procedural Posture:
Santos’s complaint initiated at the Labor Arbiter (LA), which ruled in his favor for illegal dismissal, ordering reinstatement and backwages payment. The National Labor Relations Commission (NLRC) affirmed with modifications, opting for separation pay over reinstatement. Upon denial of a Motion for Reconsideration by the NLRC, Tiamsic appealed to the Court of Appeals (CA), which upheld the NLRC’s decision. The rejective stance of the CA on a subsequent Motion led Tiamsic to escalate the matter to the Supreme Court (SC) via a petition for review on certiorari.
### Issues:
1. Did the CA infringe upon the employer’s right to dismiss an employee for reasons harmful to the employer’s interests?
2. Was the CA’s decision inconsistent with Supreme Court precedents, specifically regarding the entitlement of the dismissed employee to only nominal damages, provided there was a valid ground for dismissal but failure to comply with the two-notice rule?
### Court’s Decision:
The Supreme Court denied the petition, affirming the decisions of the CA, NLRC, and LA. It upheld that Santos was illegally dismissed without just cause and without due procedural process. Both substantive and procedural aspects of due process were violated: the company failed to prove Santos’s alleged misconduct with substantial evidence, and Santos was not accorded the proper notices or the opportunity to defend himself.
### Doctrine:
The case reiterates the doctrine that for a dismissal to be valid, it must comply with both substantive and procedural due process. The employer must prove a just or authorized cause for dismissal and follow legal procedures for termination, including providing two written notices and an opportunity for the employee to present their side.
### Class Notes:
– Illegal Dismissal: Burden of proof is on the employer. Dismissal must be substantiated by just cause and adhere to procedural due process.
– Procedural Due Process: Requires two written notices (Notice to Explain and Notice of Termination) and an opportunity for the employee to defend themselves.
– Substantial Evidence: The quantum of proof in labor cases, meaning more than a mere scintilla and as such evidence that a reasonable mind might accept as adequate to justify a conclusion.
### Historical Background:
This case underscores the stringent requirements set by Philippine labor law for legally terminating an employee, highlighting the balance between an employer’s right to dismiss for just cause and the employee’s right to security of tenure and due process.
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