FACTS ISSUE: WON Respondent Tequillo was illegally dismissed

Petitioner Stanfilco is a domestic corporation operating a banana RULING

plantation in Bukidnon. Respondent Tequillo was a Farm Associate
employed by Stanfilco from January 5 2004 until his termination on May 24 The petition is meritorious. Under the law, an employee's termination may
2010. Stanfilco hosts a weekly company-initiated employee gathering be justified on the ground of serious misconduct. Misconduct is generally
known as “Kaibigan Fellowship”. While such assembly touches on matters defined as "a transgression of some established and definite rule of action,
not work-related, it is also used as a venue for company announcements a forbidden act, a dereliction of duty, willful in character, and implies
and production updates. On September 12 2009, during such assembly in wrongful intent and not mere error in judgment." In labor cases,
which everyone was required to attend, Tequillo opted to go on a drinking misconduct, as a ground for dismissal, must be serious-that is, it must be of
spree at the farm shed area of Stanfilco’s premises with his fellow workers. such grave and aggravated character and not merely trivial or unimportant.
A certain Gayon chanced upon them and eventually joined. Tequillo was In addition, the act constituting misconduct must be connected with the
expressing his disappointment towards Stanfilco by not giving him duties of the employee and performed with wrongful intent. Hence, for an
performance incentives, and advised Gayon, who was not a regular employee's termination to be justified on the ground of serious
employee at that time, not to work any longer as he might suffer the same misconduct, the following requisites must concur:
fate as he did. However, Gayon told Tequillo to air his grievances to
(a) The misconduct must be serious;
management, which irked Tequillo, who proceeded to maul him.
(b) It must relate to the performance of the employee’s duties,
On September 15 2009, Tequillo was sent a memorandum requiring him to showing that the employee has become unfit to continue working
explain why no disciplinary action should be taken against him for the for the employer; and
drinking and mauling incident. Tequillo invoked self-defense, but stayed (c) It must have been performed with wrongful intent
silent on the drinking issue. Administrative hearings were held twice, on
In this case, the CA refused to characterize Tequillo's acts as work-related
October 17 2009 and February 2 2010. Stanfilco found Tequillo’s
because he was not a participant in the "Kaibigan Fellowship". Petitioner
explanations unsatisfactory, and eventually terminated him on May 24
countered that the "Kaibigan Fellowship" was held during work hours and
2010 for serious misconduct. Thus, Tequillo filed a complaint for illegal
within company premises.
dismissal.
The Court partly agrees. Both petitioner and the CA erred in equating
The Labor Arbiter (LA) ruled that Tequillo’s dismissal was valid saying that
work-relatedness to the time when and place where the offense was
the drinking and mauling incident was duly proved, which constitutes
committed. To be sure, physical violence between and among employees
serious misconduct and willful disobedience to company rules. On appeal,
may constitute serious misconduct regardless of whether such violence
the NLRC reversed the LA decision stating that Tequillo was illegally
occurred during working hours and within company premises. Although
dismissed since he was not performing official work at the time he mauled
the Court has recognized that workplace violence may constitute serious
Gayon, thus it was not work-related. On appeal, the CA affirmed the NLRC
misconduct, it has also held that not every fight within company would
decision.
automatically warrant dismissal from service. Jurisprudence requires that the discipline expected by petitioner from its employees. That Tequillo is
the confrontation be "rooted on workplace dynamics" or connected with ill-suited to continue working is shown by his perverse attitude and by the
the performance of the employees' duties. Stated otherwise, time and possibility that the attack may be repeated. On the other hand, his
location do not, by themselves, determine whether violence should be wrongful intent is shown by the arbitrary and unfounded manner in which
classified as work-related. Rather, such determination will depend on the he attacked Gayon. Hence, all the requisites of serious misconduct are
underlying cause of or motive behind said violence. Clearly then, the fact present in this case. PETITION GRANTED CA DECISION REVERSED AND SET
that the act complained of in this case, particularly the mauling of Gayon, ASIDE.
took place at the plantation and while the "Kaibigan Fellowship" was being
held is of no moment. The enquiry should be into the proximate cause of
or the motive behind the attack.

From the Court's perspective, the work-relatedness of and wrongful intent

behind Tequillo's violent conduct cannot be questioned. Tequillo himself
admitted that he mauled Gayon out of emotional disturbance, which was
ultimately caused by petitioner's refusal to provide the former employee
with a productivity incentive. The attack was clearly unfounded, as it
remains undisputed that petitioner's refusal to furnish said incentive was
due to Tequillo's failure to meet his work quotas. Worse, Gayon had said or
done nothing to sufficiently provoke the attack. Therefore, while it may be
true that Tequillo acted out of resentment towards petitioner, the same
resentment was essentially attributable to his own work-related neglect. It
follows, then, that the attack was connected to the sub-standard
performance of Tequillo's duties, and that it was fundamentally rooted in
his confounded notion of workplace dynamics.

Further, there exists a substantial basis to believe that Tequillo is capable

of repeating his violent act. This shows that Tequillo may be irked without
reason and that he possesses an egregious disposition that is detrimental
not only to petitioner, but to his co-employees. Verily, to allow him to
remain in petitioner's employ would put his fellow farm workers at risk of
physical harm every time he feels wronged.

Taken together, these show that Tequillo's violent act amounted to serious
misconduct. The incident disturbed the peace in the farm and breached