CASE DIGEST
Philippine Airlines,
Inc. v. Yañez
G.R. No. 214662, [March 2, 2022]
THIRD, LOPEZ, M.
Suspension of employment; Sexual Harassment
Employers must observe procedural due process and comply with the requirements of relevant law when investigating and imposing disciplinary measures on employees accused of misconduct, including sexual harassment. When due process is complied with, the court will respect the employer's prerogative to impose disciplinary sanctions on erring employees, provided that such actions are undertaken in good faith and in accordance with applicable laws and regulations.
Frederick Yañez, a supervisor at PAL Passenger Handling Division, received a notice detailing an alleged incident involving him and flight attendant Nova Sarte. Sarte reported that Yañez had touched her inappropriately during a ground stop before their return flight, and she had experienced similar incidents previously. Despite Yañez's denial of the charges, PAL proceeded with an administrative hearing and subsequently suspended him for three months based on the findings of the investigating committee. Dissatisfied, Yañez filed a complaint for illegal suspension against PAL, claiming salary during the suspension period and moral damages.
Whether PAL's actions, including the
suspension of Yañez, complied with procedural due process and the requirements
of Republic Act No. 7877 (Anti-Sexual Harassment Act).
YES. The Supreme Court ruled in favor of Philippine
Airlines, Inc. (PAL), holding that Yañez's suspension was valid and reasonable.
The Court emphasized that Yañez was adequately informed of the charges against
him and was given ample opportunity to present his side during the
investigative process. PAL's actions were found to be following the procedural
requirements of Republic Act No. 7877 concerning the investigation of sexual
harassment complaints. The Court also affirmed PAL's right to impose
disciplinary measures on its employees, provided that such measures are done in
good faith and in accordance with applicable laws and regulations. Therefore,
Yañez's suspension for three months was deemed legal, and his claims for salary
during the suspension period and damages were dismissed.
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