G.R. No. 219430 . November 07, 2016
JINKY S. STA. ISABEL, PETITIONER, VS. PERLA COMPAÑIA DE SEGUROS, INC., RESPONDENT.

FACTS

Petitioner Jinky S. Sta. Isabel was hired as a Claims Adjuster by respondent Perla Compañia de Seguros, Inc. on February 27, 2006. Perla discovered Sta. Isabel owned a separate insurance agency, JRS Insurance Agency, leading to a conflict of interest. Perla issued directives to manage this conflict. Subsequently, Sta. Isabel received several Notices to Explain for poor service towards clients of other agencies (PAIS and Ricsons). She submitted an explanation for the PAIS incident but failed to do so for the Ricsons incident. Perla issued a Final Written Warning on November 22, 2012, and a Final Directive ordering her to report to the Head Office. Sta. Isabel did not report as directed but instead met with a company officer at a restaurant. On November 26, 2012, Perla issued a Notice to Explain for failing to report and a Notice of Termination on the ground of insubordination. Sta. Isabel filed a complaint for illegal dismissal and other monetary claims. The Labor Arbiter dismissed the complaint, finding valid dismissal based on her disrespectful letter of November 27, 2012, which constituted serious misconduct and insubordination. The NLRC reversed, holding her refusal to report was not willful disobedience and her dismissal was unlawful. The Court of Appeals reinstated the Labor Arbiter’s decision, finding her conduct constituted insubordination.

ISSUE

Whether the Court of Appeals erred in finding that petitioner Jinky S. Sta. Isabel was validly dismissed on the ground of insubordination or willful disobedience.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court held that Sta. Isabel’s dismissal was for a just cause. Her repeated and deliberate refusal to comply with the lawful orders of her employer to report to the Head Office to explain her side regarding the administrative charges constituted willful disobedience. The orders were lawful, reasonable, and made known to her. Her failure to obey was characterized by a wrongful and perverse attitude. Furthermore, her letter dated November 27, 2012, which imposed conditions for her appearance, confirmed her defiant attitude. The totality of her actions amounted to insubordination, a valid ground for dismissal under Article 297 (formerly Article 282) of the Labor Code. The Court also found that she was afforded procedural due process, as she was given notices and opportunities to explain.