CASE 16: China Banking Corporation v. Borromeo (G.R. No. 156515, October 19, 2004)

Management Prerogative in Employee Discipline

Employers have the right to discipline employees and impose appropriate penalties, including restitution for losses caused by employee misconduct.

Due Process in Labor Cases (Article III, Section 1, 1987 Constitution)

The Court ruled that due process was observed because Borromeo was given the opportunity to explain his actions before any penalty was imposed.

Summary Nature of Labor Proceedings

Labor arbiters are not bound by technical rules of procedure and evidence. They can decide cases based on position papers without requiring full-blown hearings.

Restitution as a Disciplinary Measure

The company’s Code of Ethics allowed restitution as a penalty for infractions leading to financial losses, even in the absence of dismissal or suspension.

Employer’s Right to Withhold Benefits

The company had the right to withhold Borromeo’s separation pay and bonuses until it recovered losses from the unauthorized DAUD/BP accommodations.

Admissions Against Interest Doctrine

Borromeo’s admission that he violated company policies and misjudged the transaction was used against him, eliminating the need for further investigation.

Factual Findings of Labor Tribunals

The Supreme Court upheld the factual findings of the Labor Arbiter and NLRC, ruling that appellate courts should respect labor tribunals’ decisions when supported by evidence.

Banking Institutions and Public Trust

Banks are required to exercise the highest level of diligence in managing financial transactions, making policy violations by officers a serious matter.

Finality of NLRC Decisions Supported by Evidence

The Supreme Court ruled that the Court of Appeals erred in remanding the case for further hearings, as the Labor Arbiter’s findings were already well-supported.