Supreme Court clarifies that material liability under Art. 124 KP applies for unaccounted cash, not Art. 122 KP requiring theft conviction.

The Supreme Court quashed the appellate court's dismissal of the employer's claim against a sales representative for unaccounted cash. The court found that while the employee failed to reconcile cash taken from customers, this did not constitute the theft required for criminal liability under Article 122 of the Labor Code. Instead, the court ruled that the proper legal basis for civil material liability was Article 124 of the Labor Code, which governs liability for entrusted property without requiring a criminal conviction. Consequently, the appellate court erred by failing to apply the correct statutory provisions and the burden of proof rules specific to Article 124.