Castillo Vs Prudential Life Plans
Castillo Vs Prudential Life Plans
FACTS: Respondent Prudentialife is an insurance company, while respondents Jose Alberto T. Alba (Alba), Atty.
Ceferino A. Patiño, Jr. (Patiño) and Rosemarie de Lemos (de Lemos) are its President, First Vice-President for
Corporate Services Group,and Assistant Vice-President for Human Resources, espectively.
Under Section 4, Article X of the parties’ Collective Bargaining Agreement (CBA), Prudentialife employees were
granted an optical benefit allowance of P2,500.00 to subsidize prescription eyeglasses for those who have
developed vision problems in the course of employment. The pertinent CBA provision states:
Section 4. Optical benefit. – The Company shall provide an amount not to exceed P2,500.00 inclusive of VAT to any
covered employee to defray the cost of eyeglasses that may be prescribed by the accredited HMO physician or
employee’s personal optometrist. The benefit can be availed of only once every two(2)years.4
Many Prudential life employees – petitioners included – availed thereof and Prudential life was flooded with
requests for reimbursement for eyeglasses the employees supposedly purchased from a single outfit/supplier,
Alavera Optical. Suspecting fraud, Prudentialife began an investigation into the matter, and on February 22, 2006, it
sent individual written Notices to Explain5 to petitioners and other employees who availed of the benefit. The
notices revealed its initial findings – that the given address and telephone number of Alavera Optical were fictitious;
that the official receipts and prescriptions issued by Alavera Optical appear to have been forged; that the eyeglasses
were grossly overpriced; and that Prudentialife was being required to pay for the eyeglasses even though they have
not been released as yet. The notices required the recipients thereof to submit their written explanation relative to
acts of dishonesty and fraud which they may have committed in connivance with Alavera Optical.
ISSUE: THE COURT OF APPEALS SERIOUSLY ERRED AND COMMITTED GRAVE ABUSE OF DISCRETION AMOUNTING TO
LACK OR IN EXCESS OF JURISDICTION WHEN IT RENDERED ITS DECISION NOT IN ACCORD WITH LAW AND
JURISPRUDENCE
HELD: In a labor case, the written statements of co-employees admitting their participation in a scheme to defraud
the employer are admissible in evidence. The argument by an employee that the said statements constitute hearsay
because the authors thereof were not presented for their cross-examination does not persuade, because the rules
of evidence are not strictly observed in proceedings before the National Labor Relations Commission (NLRC), which
are summary in nature and decisions may be made on the basis of\position papers.