GR 273562; (February, 2025) (Digest)
G.R. No. 273562 , February 24, 2025
SANTIAGO DJ. SILLANO, PETITIONER, vs. JGC PHILIPPINES, INC. AND/OR VIRGILIO SAAVEDRA, ERIC TANJUTCO, AND LOLITA FALLER, RESPONDENTS.
FACTS
Petitioner Santiago dJ. Sillano was employed by respondent JGC Philippines, Inc. (JGC) as a Junior Engineer on June 1, 1994, and was a Senior Engineer by the time of his termination on February 16, 2004. During his employment, Sillano created five computer programs. A dispute arose in January 2004 regarding the ownership of these programs: Sillano claimed ownership as the creator, while JGC claimed ownership, asserting the programs were created in the course of his employment. Sillano activated security features on the programs, rendering them inaccessible to JGC. On January 14, 2004, JGC served Sillano with a Notice to Explain and Notice of Preventive Suspension for alleged infractions. JGC demanded he unlock the programs and surrender the source codes. Sillano refused, contesting JGC’s ownership. On February 16, 2004, JGC terminated Sillano’s employment for willful disobedience. Sillano filed a complaint for illegal dismissal, illegal suspension, and monetary claims before the NLRC. Both parties presented Certificates of Copyright Registration for the programs. The Labor Arbiter ruled the dismissal was for a just cause. The NLRC, on appeal, reversed, finding the preventive suspension valid but the dismissal illegal, as JGC failed to prove a just cause, especially in light of a subsequent Intellectual Property Office (IPO) Decision dated September 28, 2007, which declared Sillano the owner of the programs. The NLRC ordered payment of separation pay and backwages. The Court of Appeals affirmed the NLRC’s ruling. Sillano filed the present Petition for Review specifically to question the legality of his suspension and his entitlement to benefits, attorney’s fees, and damages.
ISSUE
The primary issue for resolution is whether the Court of Appeals erred in affirming the NLRC’s findings that Sillano’s preventive suspension was valid but his dismissal was illegal, and in denying his claims for benefits, attorney’s fees, and damages.
RULING
The Supreme Court DENIED the Petition for Review. The Decision and Resolution of the Court of Appeals were AFFIRMED with MODIFICATION that the monetary award in favor of Sillano shall earn legal interest at 6% per annum from the date of finality of the Decision until full payment.
The Court held that the petition raised questions of fact, which are not reviewable in a Rule 45 petition. The factual findings of the NLRC, affirmed by the CA, are final and conclusive when supported by substantial evidence. The Court found no compelling reason to deviate from this rule. The CA correctly upheld the NLRC’s findings that JGC complied with procedural due process in the dismissal but failed to establish a just cause for termination, as Sillano’s refusal to obey the order was not tainted with a wrongful attitude given the pending ownership dispute, later resolved in his favor by the IPO. The CA also correctly ruled that Sillano’s preventive suspension was valid as it complied with legal requisites. The Court modified the CA decision only with respect to the imposition of legal interest on the monetary award.