20-St. Lukes v. Sanchez

Labor Standards: Protection to
St. Luke’s Medical Center, Inc. v. Sanchez Employer, Management

20
prerogative
G.R. No. 212054 March 11, 2015 J. Perlas-Bernabe Besa, H.
Petitioners: Respondents:
St. Luke’s Medical Center, Inc. (SLMC) Maria Theresa V. Sanchez
Sec. 20, Art. II (CONST). The State recognizes the indispensable role of the private sector, encourages private
enterprise, and provides incentives to needed investments.
Facts
 Sanchez was a Staff Nurse of SLMC assigned at the QC Pediatric Unit who was terminated for purported
violation of SLMC’s Code of Discipline, Sec. 1, Rule 1 on Acts of Dishonest, i.e. Robbery, Theft, Pilferage,
and Misappropriation of Funds.
 At the end of her shift on May 29, 2011, the Security Guard on duty (SG Manzanade) found a pouch in
Sanchez’s bag containing an assortment of medical stocks (syringes, gloves, cotton balls, venofix,
neoflon, and micropore).
 Sanchez was directed to write an undated letter of apology where she expressly admitted bringing out
the questioned items. An initial investigation was conducted, followed by a notice to explain. Sanchez
submitted an Incident Report Addendum where she explained that the items came from medication
drawers of patients who had already been discharged, and that this was common practice among the
other staff. She then put the pouch inside the lowest drawer of the bedside table in the treatment room
for use in immediate procedures in case replenishment of stocks gets delayed. However, on the day of
the incident, she failed to return the pouch inside the medication drawer upon getting her tri-colored
pen and calculator and, instead, placed it inside her bag. Eventually, she forgot about the same as she
got caught up in work, until it was noticed by the guard on duty on her way out of SMLC's premises.
 Sanchez was placed under preventive suspension until the conclusion of the investigation by SLMC’s
Employee and Labor Relations Department (ELRD). After hearing her side of the story, SLMC informed
her of their decision to terminate her employment. This prompted her to file a complaint for illegal
dismissal before the NLRC.
 Sanchez maintains that she is innocent, claiming that she had no intention to bring the items outside of
SLMC; that she could not be found guilty of pilferage since the items were neither the possession of SLMC
nor of its employees; that SLMC did not file any criminal charges; and that her admission on the
handwritten letter was inadmissible for being unconstitutional as she was unassisted by counsel at that
time.
Issues Ruling
1. W/N Sanchez was illegally dismissed by SLMC 1. Yes
Rationale
 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. Labor laws discourage interference in employers’ judgment concerning the conduct of their
business.
 Among the employer’s management prerogative 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. Employee has
the corollary duty to obey all reasonable rules, orders, and instructions of the employer; and willful or
intentional disobedience, as a general rule, justifies termination of the contract of service and the
dismissal of employees.
1
 Art. 296, LC. Termination by Employer (a) Serious misconduct or willful disobedience by the employee
of the lawful orders of his employer or his representative in connection with this work.
 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. = It is clear that the company policies are reasonable and lawful, sufficiently known and
evidently connected to their work = Dismissal was for a just cause.
 Sanchez was validly dismissed by SLMC for her willful disregard and disobedience of Sec. 1, Rule 1 of the
SLMC Code of Discipline, which reasonably punishes acts of dishonesty—the act is obviously connected
with her work as a staff nurse tasked with the proper stewardship of medical supplies. She also made a
categorical admission in her handwritten letter saying “kahit alam kong bawal ay nagawa kong
makapag-uwi ng gamit”.
 Sec.1, Rule 1 of the SLMC Code of Discipline is further supplemented by the company policy requiring
the turn-over to excess medical supplies/items for proper handling and providing restriction on taking
and bringing such items out of SLMC premises without proper authorization, which Sanchez was equally
aware of.
 There lies no competent basis to support the common observation of the NLRC and CA that the act was
a tolerated practice among nurses at the Pediatric Unit.
 Absence of damage to SLMC does not mitigate nor negate the employee’s liability. A criminal case is not
necessary to find just cause for termination of employment.

20-St. Lukes v. Sanchez

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Labor Standards: Protection to

St. Luke’s Medical Center, Inc. v. Sanchez Employer, Management

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