The Supreme Court upheld the dismissal of a school physician for gross inefficiency and negligence in keeping student medical records. This ruling underscores the importance of diligence and competence in professional duties, especially in roles concerning health and safety, highlighting that failing to maintain proper records and systems can justify termination, even after years of service.

Medical Records Under Scrutiny: When Negligence Justifies Dismissal

Dr. Phylis C. Rio, a school physician at Colegio de Sta. Rosa-Makati, faced termination after discrepancies were found in student medical records. The school cited grave misconduct, dishonesty, and gross neglect of duty, pointing to instances of missing records, examinations not conducted, and records predating student enrollment. While Dr. Rio attributed these issues to a lost cabinet key and subsequent errors, the school argued that her overall inefficiency and lack of a proper record-keeping system warranted dismissal. This case raises the critical question: How much negligence is enough to justify the termination of an employee entrusted with important responsibilities?

The legal basis for the dismissal rests on Article 282 of the Labor Code, which allows an employer to terminate employment for causes such as gross and habitual neglect of duties. Additionally, Section 94 of the 1992 Manual of Regulations for Private Schools includes “gross inefficiency and incompetence” and “negligence in keeping school or student records” as grounds for termination. The Supreme Court, in this case, emphasized the connection between gross inefficiency and gross neglect, noting that both involve omissions that cause harm. To constitute gross neglect, the negligence must be characterized by a want of even slight care, acting or omitting to act willfully and intentionally, with a conscious indifference to consequences.

The court’s decision hinged on the factual findings regarding Dr. Rio’s performance. The records revealed instances of medical examinations scheduled on weekends, failure to conduct examinations for multiple consecutive years, a lack of medical records for some students, and records existing before students were even enrolled. While Dr. Rio argued that the discrepancies arose from a lost key to the medical records cabinet and subsequent errors during data entry, the court found her explanation unconvincing. The Court of Appeals pointedly noted, that she had not been maintaining and updating the medical records.

x x x If petitioner had been attentive to her work as she claims, this cabinet could not have been left dormant for two years as she would have been regularly updating her records and checking on them. x x x Assuming that the cabinet was indeed locked, the fact that she did not bother to have it opened for two years only showed that she had no need to use the files contained therein because she had not been maintaining and updating the medical records as she had not been performing her job actively conducting routine physical examination on the students as required of her.^[19] x x x

The Supreme Court agreed with the Court of Appeals, emphasizing that even if Dr. Rio’s explanation were true, her failure to establish and maintain a proper system for managing student medical records constituted gross inefficiency and negligence. This ruling underscores the principle that employers have a right to expect a certain level of competence and diligence from their employees, especially when those employees are entrusted with responsibilities vital to the health and safety of others.

Building on this principle, the decision also touches upon the standard of review in labor cases. As stated in Mercado v. AMA Computer College-Parañaque City, Inc., the appellate court may examine the factual findings of the NLRC if the same are not supported by substantial evidence. In Montoya v. Transmed Manila Corporation, the Court reiterated that the question is: Did the CA correctly determine whether the NLRC committed grave abuse of discretion in ruling on the case? This means that the Court’s role is not to re-evaluate the merits of the case but to determine whether the NLRC acted with grave abuse of discretion, meaning a capricious or whimsical exercise of judgment equivalent to a lack of jurisdiction.

In this case, the Supreme Court found no evidence that the NLRC acted with grave abuse of discretion. The Court emphasized that Dr. Rio failed to demonstrate that the NLRC exercised its judgment capriciously, whimsically, arbitrarily, or despotically. The Court determined that based on the evidence presented, Colegio de Sta. Rosa-Makati had sufficient reason to terminate Dr. Rio’s employment based on gross inefficiency, incompetence, and negligence in maintaining student records.

FAQs

What was the key issue in this case?	The central issue was whether Colegio de Sta. Rosa-Makati legally dismissed Dr. Phylis C. Rio based on allegations of gross inefficiency and negligence in handling student medical records. The Supreme Court assessed if the NLRC committed grave abuse of discretion in reversing the Labor Arbiter’s decision in favor of Dr. Rio.
What is gross neglect of duty?	Gross neglect of duty refers to negligence characterized by a lack of even slight care, acting or omitting to act willfully and intentionally, with a conscious indifference to the consequences for others. It involves a significant deviation from the standard of care expected in a particular role.
What does grave abuse of discretion mean?	Grave abuse of discretion occurs when a court or tribunal exercises its judgment in a capricious, whimsical, arbitrary, or despotic manner, equivalent to a lack of jurisdiction. It implies an evasion of a positive duty or a virtual refusal to perform a duty required by law.
What evidence supported the school’s decision to dismiss Dr. Rio?	Evidence included instances of medical examinations scheduled on weekends, failure to conduct medical examinations for all students for multiple years, missing medical records, and records predating student enrollment. This evidence collectively pointed to a pattern of negligence and inefficiency in her duties.
What was Dr. Rio’s defense against the charges?	Dr. Rio claimed that discrepancies were due to a lost cabinet key and subsequent errors in transferring temporary records. She argued that these circumstances mitigated her responsibility for the inaccuracies in the medical records.
Why did the court reject Dr. Rio’s defense?	The court rejected her defense because she waited two years to have the cabinet opened, even though updating medical records was part of her duties. The court stated she should have been actively maintaining and updating the records.
What is the significance of Article 282 of the Labor Code in this case?	Article 282 of the Labor Code allows employers to terminate employment for causes like gross and habitual neglect of duties. This provision provided the legal basis for the school’s decision to dismiss Dr. Rio based on her negligent performance of her responsibilities.
How does Section 94 of the Manual of Regulations for Private Schools relate to the case?	Section 94 of the Manual of Regulations for Private Schools specifically lists “gross inefficiency and incompetence” and “negligence in keeping school or student records” as grounds for terminating employment. This section reinforced the legal justification for Dr. Rio’s dismissal.
What is the standard of review for NLRC decisions in the Court of Appeals?	The Court of Appeals reviews NLRC decisions to determine if the NLRC committed grave abuse of discretion, not to re-evaluate the merits of the case. The appellate court examines whether the NLRC’s judgment was exercised capriciously, whimsically, arbitrarily, or despotically.

This case serves as a reminder to employees, particularly those in positions of trust and responsibility, of the importance of diligence and competence in performing their duties. Failure to maintain proper systems and diligently execute assigned tasks can lead to serious consequences, including termination. This ruling reinforces the employer’s right to demand a standard of care that ensures the safety and well-being of those they serve.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: DR. PHYLIS C. RIO VS. COLEGIO DE STA. ROSA-MAKATI, G.R. No. 189629, August 06, 2014