Manila Electric Company vs. Argentera

Absent an express provision on forfeiture of benefits in a company policy or contractual stipulation under an individual or collective contract, an employee's rights, benefits, and privileges are not automatically forfeited upon dismissal. A valid dismissal for serious misconduct does not, by itself, extinguish monetary benefits that accrued during the employer's investigation until the employee's termination; termination is without prejudice to rights, benefits, and privileges under the applicable individual or collective agreement or voluntary employer policy or practice.

Manila Electric Company is a public utility engaged in electric power distribution in Metro Manila and various provinces. Apolinar A. Argentera began working for Meralco on January 16, 1990 and was promoted to acting foreman in January 2012. He was assigned to Crew T-2319 under the Central Operation and Maintenance Substation Office, which maintained Meralco substations, including the retired Forbes Park substation. His employment was governed by Meralco's Code on Right Employee Conduct/Code on Employee Discipline and a Collective Bargaining Agreement.

Apolinar A. Argentera began working for Manila Electric Company on January 16, 1990, and by January 2012 he had been promoted to acting foreman. Meralco, a public utility distributing electric power to Metro Manila and several provinces, operated numerous substations, including the retired Forbes Park substation. Argentera was assigned to Crew T-2319 under the Central Operation and Maintenance Substation Office, which was responsible for maintaining the substation. On August 6, 2012, Crew T-2319, composed of Argentera, Antonio C. Tizon, and reliever Edward F. Garcia, went to the Forbes Park substation. They told guard Gil M. Udag that they would inspect the equipment, and because Argentera and Tizon were the crew members who usually inspected substations, Udag allowed them inside and gave them a Substation Action Form to indicate the activities done and items removed. Argentera and Tizon prevented Udag from approaching the area, claiming it was dangerous. After the crew left, Udag checked the area and found three disconnect switch blades missing, even though these were not listed in the Substation Action Form; he recorded the incident in the security logbook.

On August 22 and 23, 2012, Argentera and Tizon returned to the Forbes Park substation to continue their inspections. Guard Roberto Mecina, Jr. allowed them to enter and gave them a Substation Action Form for each day. As before, Mecina was prevented from going near the area where Argentera and his crew were working. After the crew left on each day, Mecina noted in the security logbook that six disconnect switch blades were missing on August 22 and another three on August 23, and in both instances the forms did not indicate that these items were removed from the premises. In October 2012, during an inventory inspection, Argentera's supervisors and team leader discovered the missing disconnect switch blades. Argentera's team leader, Enrique B. Santos, reported the missing items to Meralco's management on October 17, 2012. On November 29, 2012, Meralco issued a Notice of Investigation against the members of Crew T-2319: Argentera, Tizon, Christian Reformina, and former reliever Garcia. Hearings were conducted and statements were submitted until January 29, 2014.

Argentera denied responsibility. According to him, on August 6, 2012, he received a text message from his supervisor, Jamar Eco, instructing him to pick up an oil pump and hose at the Forbes Park substation; he went there with Tizon while Garcia remained in the truck. On August 22, 2012, he went to the substation to bring SAF pads previously requested by a guard. On August 23, 2012, his crew was checking the disconnect switch at the Malibay substation. He claimed that on all these dates they returned to base at around 4:00 p.m., but when confronted about returning beyond 4:00 p.m., he said he could not remember. Tizon corroborated Argentera's account. He claimed they did not bring tools but simply loaded the oil pump on the truck and returned to base before 4:00 p.m. on August 6, 2012; that on August 22, 2012, they went to the Forbes Park substation to give SAF pads to the requesting guards and he only went inside to use the bathroom; and that he did not remember why they arrived beyond 4:00 p.m. on August 6 and 23, speculating that they must have been delayed by traffic.

Garcia executed two affidavits. In his first affidavit, he alleged that he was assigned to Crew T-2319 on August 6, 2012 because of insufficient personnel. He remained in the truck as Argentera and Tizon entered the Forbes Park substation with tools. He said he did not see what they were doing inside the truck and, when they returned, he did not see them carry anything aside from the tools they had brought. In his second affidavit, Garcia changed his account. He claimed that from inside the truck he saw Tizon on top of the disconnect switches removing the blade contact and, with Argentera, returning with the blades and excess bolts and nuts, which they stored at the back of the truck. Eco, the supervisor assigned to Argentera's crew, said the crew was in charge of retiring the Forbes Park substation, in which the crew would dismantle parts that could not be brought outside the substation. He said he confronted Argentera and Tizon upon discovering that they had pulled out the missing blades, and that the two admitted doing so. Santos, the team leader of the Central Operation and Maintenance Office in charge of giving crew assignments, denied having instructed Argentera's crew to remove an oil pump from the substation on August 6, 2012. He likewise denied having instructed the crew to pull out the blades, asserting that Argentera and Tizon had admitted removing them.

On January 29, 2014, Meralco issued a Disciplinary Process Report recommending that Argentera and Tizon be dismissed from employment. The case was also referred to Meralco's legal department for the possible filing of qualified theft charges; Garcia and Reformina were not held liable. On February 18, 2014, Meralco issued a Notice of Decision terminating Argentera and Tizon from employment for violating its Code on Right Employee Conduct/Code on Employee Discipline. Argentera was notified of the decision on February 19, 2014. Specifically, Argentera and Tizon were held to have committed: (a) leaving work area, loafing, loitering, sleeping, or performing personal matters while on duty; (b) theft of property belonging to another person committed during working time or on company premises, or of company property regardless of place or time; (c) willful disobedience by the employee of the lawful orders of his superior in connection with his work; (d) any improper act, omission, conduct, or behavior analogous to the provisions of the rule and prejudicial to the interest of the company; and (e) unauthorized use, lending, or improper care of company property. The notice also indicated that Argentera was terminated based on Article 282 of the Labor Code for serious misconduct or willful disobedience.

On March 14, 2014, Argentera filed a Request for Assistance with the NCR-Arbitration Branch of the Department of Labor and Employment. On May 12, 2014, Meralco filed a Complaint-Affidavit for qualified theft against Argentera and Tizon. Subsequently, Reformina executed an affidavit supporting the charge, stating that he and the rest of Crew T-2319 went to the Forbes Park substation twice or thrice a week from January to August 2012. During these visits, Argentera and Tizon would allegedly illegally dismantle retirable materials to sell to junkshops. Argentera allegedly decided when to go to the substation and Tizon selected the junkshop. The two would evade the guards by placing retirable materials inside the toolbox on the truck and misdeclaring items in the Substation Action Form. The proceeds from the sale of these items were allegedly used to buy illegal drugs. After mediation failed, Argentera filed a Complaint for illegal dismissal against Meralco and its president, Manny V. Pangilinan. In his Complaint, Argentera claimed entitlement to a P70,000.00 lump sum under the Collective Bargaining Agreement and alleged that Meralco failed to pay him a P20,000.00 signing bonus, 2012 and 2013 Christmas bonuses, monetized sick and vacation leave benefits, a 2012 anniversary bonus, 2012 and 2013 midyear bonuses, and performance incentive plan benefits.

The Labor Arbiter found sufficient evidence showing that Argentera and Tizon were responsible for the missing disconnect switch blades. The guards positively identified Argentera and Tizon as the ones who entered the Forbes Park substation on August 6, 22, and 23, 2012, and after they left, several disconnect switch blades were missing; the guards were prevented from approaching the work area on the claim that it was dangerous even though the substation was already retired and de-energized; and the forms did not indicate that the blades were pulled out. Garcia testified that Argentera and Tizon removed the blades and loaded them at the back of the crew truck. Reformina attested that from January to August 2012 they went to the Forbes Park substation two to three times a week, led by Argentera and Tizon, where they dismantled disconnect switch blades and other retirable materials and loaded them at the back of the truck, and that Argentera sold the items to junkshops. Argentera's supervisor and team leader never instructed or authorized him and Tizon to go to the Forbes Park substation on August 6, 22, and 23, 2012, or to remove or dismantle the blades. Against these positive declarations, Argentera offered only a general denial and presented no witness to support his innocence. The National Labor Relations Commission affirmed these findings, noting that the guards could not have caught Argentera and Tizon in the act because they were prevented from approaching the area, and that Reformina's affidavit detailed the modus operandi, which Argentera failed to refute. The Court of Appeals likewise found no showing that Argentera was preventively suspended during the investigation or that the Collective Bargaining Agreement indicated reasons for forfeiting an employee's benefits.

• Meralco (G.R. No. 224729) — Validity of Dismissal: Meralco alleged that Argentera was validly dismissed for stealing the disconnect switch blades.
• Meralco — Award of Monetary Benefits: Meralco argued that the Court of Appeals gravely erred in upholding the award of separation pay and other monetary benefits to Argentera despite his valid dismissal.
• Meralco — Daabay and Forfeiture: Relying on Daabay vs. Coca-Cola Bottlers Philippines, Inc., Meralco maintained that the award of monetary and other benefits to a validly dismissed employee for serious misconduct was akin to financial assistance or separation pay, which is granted only when the dismissal is for causes other than serious misconduct or those reflecting the employee's moral character; thus Argentera was not entitled to such award.
• Meralco — Social Justice and Bonuses: Meralco added that social justice, the law, and the collective bargaining agreement do not protect an errant worker who committed serious misconduct, and that Argentera's bonuses pending investigation depended on the results of the investigation.
• Argentera (G.R. No. 225049) — Sufficiency of Evidence: Argentera alleged that the loss of the disconnect switch blades was not proven because no inventory for the Forbes Park substation was presented.
• Argentera — Witness Credibility: He discredited Garcia's testimony because Garcia first testified that he did not see Argentera take the blades but later recanted in favor of Meralco; he argued that Eco's testimony was not credible because it was inconsistent with human experience and there was no reason for him to admit taking the blades; and he claimed that Reformina's testimony was hearsay, not based on personal knowledge.
• Argentera — Substantial Evidence and Due Process: He asserted that his culpability was not proven with substantial evidence, that a finding of probable cause cannot substitute the burden of evidence in the illegal dismissal case, and that he was denied procedural due process because he was not allowed to test the credibility of the witnesses against him.
• Argentera — Timeliness and Indigency: He refuted the claim that his Petition was filed out of time, arguing that since the extended period fell on a Saturday, his Petition was timely filed on the next business day, August 1, 2016; he also sought to litigate as an indigent.

• Argentera (Respondent in G.R. No. 224729) — CBA and Forfeiture: Argentera argued that the Collective Bargaining Agreement serves as the law between the parties and that, absent any showing of forfeiture of benefits in its provisions or any company policy, he is entitled to bonuses and benefits; he noted that no law or jurisprudence indicates an automatic forfeiture of benefits and bonuses for an employee's serious misconduct.
• Meralco and Pangilinan (Respondents in G.R. No. 225049) — Timeliness: They alleged that Argentera's Petition should be summarily dismissed because it was filed on August 1, 2016, one day after the extended period on July 30, 2016.
• Meralco and Pangilinan — Validity of Dismissal: They argued that the decision to dismiss Argentera was valid, supported by the exhaustive investigation Meralco conducted, and that the labor tribunals' findings, as affirmed by the Court of Appeals, should be accorded finality.

• Pauper Litigant: Whether Apolinar A. Argentera is qualified to be a pauper litigant.
• Timeliness: Whether Argentera's Petition in G.R. No. 225049 was timely filed within the extended period.
• Review of Factual Findings / Validity of Dismissal: Whether this Court may review the factual findings of the lower courts in sustaining the validity of Argentera's dismissal for stealing Meralco's disconnect switch blades.
• Monetary Benefits: Whether Argentera is entitled to the award of monetary benefits.
• Forfeiture of Benefits: Whether these benefits are automatically forfeited upon a finding of cause to dismiss an employee.

• Pauper Litigant: Yes. Although Argentera did not comply with the twin criteria of Rule 141, Section 19, he showed indigency under Rule 3, Section 21 and was exempt from paying legal fees.
• Timeliness: Yes. July 30, 2016 fell on a Saturday, so the extended deadline moved to the next working day, August 1, 2016, when the Petition was filed.
• Review of Factual Findings / Validity of Dismissal: No. A Rule 45 petition generally raises only questions of law, and Argentera failed to substantiate any recognized exception; the dismissal for stealing was supported by substantial evidence.
• Monetary Benefits: Yes, in part. Argentera is entitled to the P70,000.00 lump sum, monetized vacation and sick leave benefits, and Christmas, anniversary, and midyear bonuses accrued during the investigation until dismissal, but not to the P20,000.00 signing bonus, longevity pay, or incentive bonus.
• Forfeiture of Benefits: No. Absent an express provision on forfeiture in a company policy or individual/collective contract, benefits are not automatically forfeited upon dismissal.

• Pauper Litigant: Rule 141, Section 19 requires gross income and property thresholds, but noncompliance does not automatically disqualify. Under Rule 3, Section 21, a party may litigate as indigent if the court is satisfied that the party has no money or property sufficient and available for food, shelter, and basic necessities for himself and his family. Algura vs. City of Naga harmonized the rules: if the applicant meets the income and property requirements, exemption is a matter of right; if not, the court sets a hearing to allow proof of indigency. Argentera submitted a Court of Appeals Resolution allowing him to litigate as an indigent, a Barangay Certificate of Indigency, and a Pasig City Social Service and Welfare Department Certificate stating his family belonged to the low-income bracket and had no financial capacity. He later submitted an Affidavit of Indigency stating he had no fixed income and his intermittent technician job was insufficient, and a Joint Affidavit of Disinterested Persons attesting to lack of property. Although he failed to comply with Rule 141, Section 19, the documents showed indigency under Rule 3, Section 21. Thus, he was declared an indigent litigant and exempt from legal fees.

• Timeliness: On June 30, 2016, Argentera filed a Motion for Extension of 30 days to file his Petition for Review on Certiorari, or until July 30, 2016, which the Supreme Court granted on July 13, 2016. Since July 30, 2016 fell on a Saturday, the extended deadline fell on the next working day, August 1, 2016. The Petition was thus timely filed. Reiner Pacific International Shipping, Inc. vs. Guevarra was cited.

• Review of Factual Findings / Validity of Dismissal: Rule 45 generally limits review to questions of law; factual findings of labor tribunals, especially when affirmed by the Court of Appeals, are conclusive and binding. The recognized exceptions must be alleged, substantiated, and proved. Argentera admitted his questions were factual and invoked that the Court of Appeals' findings were speculative and unsupported by substantial evidence. However, to determine validity of dismissal, only substantial evidence is required, not proof beyond reasonable doubt; it is enough that there is some basis for the misconduct or reasonable ground to believe the employee is responsible. The Labor Arbiter found sufficient evidence: guards Udag and Mecina positively identified Argentera and Tizon entering the Forbes Park substation on August 6, 22, and 23, 2012, and after they left, blades were missing; they prevented guards from approaching despite the substation being retired and de-energized; they did not declare the pulled-out items in the Substation Action Form. Garcia testified that Argentera and Tizon removed the blades and loaded them at the back of the truck. Reformina attested to the modus operandi of dismantling and selling retirable materials. Supervisors denied authorizing the removal. Argentera offered only general denial and no witness. The National Labor Relations Commission affirmed, noting the guards' familiarity with equipment and that Reformina's affidavit was unrebutted. Even discounting Garcia's testimony, other testimonies implicated Argentera. Eco's and Reformina's testimonies were not overcome by bare allegations; the alleged text message instruction was not presented and Eco denied giving it. The loss was established by inventory and logbook entries. Thus, the dismissal was supported by substantial evidence and the factual findings bind the Court.

• Monetary Benefits: The crux is the propriety of the award despite valid dismissal. Preventive suspension is a management prerogative authorized by the Omnibus Rules; unless preventively suspended, an employee can continue working and earning wages, benefits, and privileges. Meralco's Code prescribes preventive suspension when the offense is punishable by dismissal, but from notice on November 29, 2012 to conclusion on January 29, 2014, Argentera was not shown to have been preventively suspended. He continued working until notified of dismissal on February 19, 2014. Meralco did not dispute that its rules and policies do not expressly provide that an employee under investigation is not entitled to benefits and bonuses. No company policy prescribed forfeiture of benefits as a penalty. Meralco relied on Daabay and Manila Water, but those pertain to separation pay or financial assistance awarded at termination. In Daabay, retirement benefits awarded as social justice were akin to financial assistance/separation pay and cannot be given to employees dismissed for serious misconduct. In Manila Water, separation pay was reversed because service record does not mitigate stealing. Neither states that a dismissed employee forfeits benefits and privileges under contract, CBA, or policy. Argentera's claims are not separation pay or financial assistance; they are monetary benefits that accrued from continued employment pending investigation. Under Omnibus Rules Book VI, Rule I, Section 7, termination for just cause does not entitle the employee to termination pay, without prejudice to rights, benefits, and privileges under applicable individual or collective agreement or voluntary employer policy or practice. Bañez vs. De La Salle University held that absent a specific forfeiture rule or CBA provision, a validly dismissed employee is entitled to earned monetary benefits under law and CBA, and the employer bears the burden to show payment. Marcos vs. National Labor Relations Commission held employees entitled to service awards, anniversary bonuses, and prorated performance bonuses earned before separation. Article 100 of the Labor Code prohibits elimination or diminution of benefits. The employer must prove the basis for forfeiture through policies, contracts, or CBA. Meralco failed. Thus, no automatic forfeiture.

• Forfeiture of Benefits: Absent express forfeiture provision, benefits are not automatically forfeited. The employer cannot unilaterally declare forfeiture of wages, benefits, and privileges that have accrued in favor of a dismissed employee. To do so would violate Article 100 of the Labor Code. Meralco's reliance on Daabay and Manila Water is misplaced because they concern separation pay or financial assistance. The CBA, Article XXI, Section 1, provides a one-time lump sum of P70,000.00 to covered supervisory employees in PG 7 to PG 12; Article XXI, Section 2 maintains unspecified economic and social benefits to regular supervisory employees. The terms are clear and unconditional. The labor tribunals and the Court of Appeals awarded the P70,000.00 benefit, and Meralco never disputed Argentera's qualification. Meralco failed to prove payment. Argentera is entitled to the P70,000.00 lump sum. His claim for a P20,000.00 signing bonus has no basis in the CBA. Longevity pay under Article XXII, Section 2 is reversed because it was not included in his monetary claims. He is entitled to the monetary equivalent of unutilized vacation and sick leave benefits; Meralco did not dispute these. For Christmas, anniversary, midyear, and incentive bonuses, Eastern Telecommunications Philippines, Inc. vs. Eastern Telecommunications Employees Union held that bonuses are demandable if made part of basic salaries or wages, stipulated in the CBA, or granted as company practice. Meralco failed to refute that it regularly gave anniversary and midyear bonuses, so these are demandable. The incentive bonus is given as an inducement for efficiency, not part of regular salary, so it is not demandable. The dispositive portion includes Christmas bonuses among the awarded benefits.

• No automatic forfeiture of accrued benefits upon dismissal — Absent an express provision on forfeiture of benefits in a company policy or contractual stipulation under an individual or collective contract, an employee's rights, benefits, and privileges are not automatically forfeited upon dismissal. Termination for just cause is without prejudice to whatever rights, benefits, and privileges the employee may have under the applicable individual or collective agreement or voluntary employer policy or practice. The employer bears the burden of proving the basis for forfeiture through its policies, employee contracts, or collective bargaining agreement. Applied here: Meralco failed to prove any express forfeiture policy or CBA provision, so Argentera retained benefits that accrued during the investigation until his dismissal.

• Substantial evidence in labor dismissal — In administrative determinations of employee culpability, only substantial evidence is required, not proof beyond reasonable doubt. It is sufficient that there is some basis for the misconduct or that the employer has reasonable ground to believe the employee is responsible. Positive testimony prevails over a general denial. Applied here: the dismissal was upheld because the guards' logbook entries, Garcia's testimony, Reformina's affidavit, and the supervisors' statements constituted substantial evidence that Argentera stole the disconnect switch blades.

• Rule 45 factual findings generally conclusive — A Petition for Review on Certiorari under Rule 45 may generally raise only questions of law. Factual findings of labor tribunals, especially when affirmed by the Court of Appeals, are conclusive and binding. The recognized exceptions must be alleged, substantiated, and proved. Applied here: Argentera's factual challenges were denied because he failed to substantiate any exception and the dismissal was supported by substantial evidence.

• Indigent litigant exemption — Rule 141, Section 19 prescribes twin criteria of gross income and property for exemption from legal fees, but noncompliance does not automatically disqualify a litigant. Under Rule 3, Section 21, the court may authorize litigation as an indigent if satisfied that the party has no money or property sufficient and available for food, shelter, and basic necessities for himself and his family. If the applicant fails the twin criteria, a hearing may be set to allow proof of indigency. Applied here: Argentera was declared an indigent litigant despite noncompliance with Rule 141, Section 19, because his affidavits and certificates showed indigency under Rule 3, Section 21.

• Demandable bonuses — A bonus is generally a gratuity or act of liberality that the recipient has no right to demand. It becomes a demandable or enforceable obligation when made part of the wage, salary, or compensation of the employee, when stipulated in the collective bargaining agreement, or when granted as a company practice. Applied here: anniversary and midyear bonuses were demandable because Meralco failed to refute that it regularly gave them; the incentive bonus was not demandable because it was an inducement for efficiency, not part of regular salary.

• Preventive suspension and continued benefits — Preventive suspension during an administrative investigation is a management prerogative authorized by the Omnibus Rules Implementing the Labor Code. Unless preventively suspended, the employee can continue working and earning wages, benefits, and privileges. Applied here: Argentera was not preventively suspended during the investigation, so he continued to earn benefits until his dismissal.

• Employer's burden to prove payment of monetary claims — The employer bears the burden of proving payment of monetary claims in the normal course of business, including legally and contractually mandated benefits. Applied here: Meralco failed to discharge this burden, so Argentera was entitled to the P70,000.00 lump sum and other accrued benefits.

• "Without an express provision on forfeiture of benefits in a company policy or contractual stipulation under an individual or collective contract, an employee's rights, benefits, and privileges are not automatically forfeited upon their dismissal." — This is the Court's core ratio, stating the primary rule that a valid dismissal does not by itself forfeit accrued benefits absent an express forfeiture provision.

• "The employer must prove the basis for the forfeiture through its policies, employee contracts, or its collective bargaining agreement. Without such proof, there is no basis to forfeit accrued monetary benefits as of the date of termination." — This passage allocates the burden of proof to the employer and explains why Meralco's failure to show any forfeiture policy or CBA provision entitled Argentera to his accrued benefits.

• "Bonuses stipulated in the collective bargaining agreement or those granted as company practice are demandable." — This defines when bonuses become enforceable obligations, supporting the award of anniversary and midyear bonuses while excluding the incentive bonus.

• "Noncompliance with the twin criteria of gross income and property under Rule 141, Section 19 does not automatically disqualify a litigant to be declared as an indigent party." — This states the rule on indigent litigants and supports the declaration that Argentera could litigate as an indigent despite failing the twin criteria.

• Daabay vs. Coca-Cola Bottlers Philippines, Inc., 716 Phil. 806 (2013) — Distinguished. The Court held that retirement benefits awarded as social justice were akin to financial assistance or separation pay and could not be given to an employee dismissed for serious misconduct; the case does not state that a dismissed employee forfeits benefits under contract, CBA, or policy.
• Manila Water Company vs. Del Rosario, 725 Phil. 513 (2014) — Distinguished. The Court reversed separation pay despite the employee's long service because stealing company property does not justify separation pay; the case does not declare forfeiture of accrued benefits and privileges.
• Bañez vs. De La Salle University, 534 Phil. 825 (2006) — Followed. Absent a specific university rule or CBA provision allowing forfeiture of benefits as a penalty for termination, a validly dismissed employee is entitled to earned monetary benefits under law and the CBA, and the employer bears the burden to show payment.
• Marcos vs. National Labor Relations Commission, 318 Phil. 172 (1995) — Followed. Employees separated from work were entitled to service awards, anniversary bonuses, and prorated performance bonuses that they had earned before separation.
• Eastern Telecommunications Philippines, Inc. vs. Eastern Telecommunications Employees Union, 681 Phil. 519 (2012) — Followed. A bonus becomes a demandable or enforceable obligation when made part of the wage, salary, or compensation, or when stipulated in the CBA or granted as company practice.
• Algura vs. City of Naga, 536 Phil. 819 (2006) — Followed. The Court harmonized the rules on indigent litigants, allowing the court to hear evidence of indigency when the applicant fails the income and property criteria under Rule 141, Section 19.
• Pascual vs. Burgos, 776 Phil. 167 (2016) — Cited for the 10 recognized exceptions to the rule that factual findings are generally not reviewable in a Rule 45 petition.
• Medina vs. Mayor Asistio, Jr., 269 Phil. 232 (1990) — Cited as the source of the 10 exceptions to the factual review rule.
• Segismundo vs. National Labor Relations Commission, 309 Phil. 160 (1994) — Cited for the rule that administrative determinations require only substantial evidence, not clear and convincing evidence or proof beyond reasonable doubt.
• Reiner Pacific International Shipping, Inc. vs. Guevarra, 711 Phil. 438 (2013) — Cited for the rule that when the extended deadline falls on a Saturday, the petition may be filed on the next working day.
• Minsola vs. New City Builders, Inc., 824 Phil. 864 (2018) — Cited for the rule that the employer bears the burden of proving payment of monetary claims in the normal course of business.
• Mandapat vs. ADD Force Personnel Services, Inc., 638 Phil. 150 (2010) — Cited for the rule that preventive suspension is a management prerogative.
• Tolentino vs. Philippine Airlines, Inc., 824 Phil. 505 (2018) and Rivera vs. Allied Banking Corporation, 722 Phil. 144 (2015) — Cited as cases upholding the validity of an employer's forfeiture policy of entitlement to benefits and privileges for a dismissed employee.
• Apo Cement Corp. vs. Baptisma, G.R. No. 176671, June 20, 2012 — Cited for the rule that positive testimony prevails over a negative one, especially where the opposing party's witnesses did not execute affidavits.

• Article 282, Labor Code — Provides the just causes for terminating employment. Meralco invoked serious misconduct or willful disobedience as the basis for Argentera's dismissal.
• Article 100, Labor Code — Prohibits the elimination or diminution of supplements or other employee benefits being enjoyed at the time of promulgation of the Code. The Court used this to hold that accrued benefits cannot be forfeited without a legal or contractual basis.
• Book VI, Rule I, Section 7, Omnibus Rules Implementing the Labor Code — States that separation from work for a just cause does not entitle the employee to termination pay, without prejudice to whatever rights, benefits, and privileges the employee may have under the applicable individual or collective agreement or voluntary employer policy or practice.
• Book V, Rule XIV, Sections 3 and 4, Omnibus Rules Implementing the Labor Code — Authorizes preventive suspension when the worker's continued employment poses a serious and imminent threat to life or property; limits preventive suspension to 30 days and requires payment of wages and benefits during an extension. Applied here: Argentera was not preventively suspended, so he continued earning benefits.
• Rule 141, Section 19, Rules of Court — Exempts indigent litigants from payment of legal fees if their gross income and that of their immediate family do not exceed double the monthly minimum wage and they do not own real property with a fair market value of more than P300,000.00. The Court found noncompliance did not automatically disqualify Argentera.
• Rule 3, Section 21, Rules of Court — Allows a party to litigate as an indigent if the court is satisfied that the party has no money or property sufficient and available for food, shelter, and basic necessities for himself and his family. Applied here: Argentera was declared an indigent litigant.
• Rule 45, Rules of Court — Governs petitions for review on certiorari, which generally may raise only questions of law. Applied here: the Court declined to review the factual findings sustaining Argentera's dismissal.
• Meralco Code on Right Employee Conduct, Rule 9, General Provisions (9) and (11) — Prescribes preventive suspension when the offense is punishable by dismissal and provides that an employee under suspension shall not be allowed to enter company premises. Cited to show that Meralco's policy allowed preventive suspension but did not provide for forfeiture of benefits.

Hernando, Inting, Delos Santos, and J. Lopez, JJ., concur.