Facts:

The case involves Lauro D. Yuseco as the respondent and 3M Philippines, Inc. as the petitioner, with the Supreme Court ruling on November 9, 2020. The dispute arose from Yuseco's employment termination; he was dismissed in 2016 under claims of redundancy. Yuseco began his employment with 3M Philippines in 1997 and held the position of Country Business Leader with a monthly salary of PHP 271,000. On November 25, 2015, he was called to a meeting by 3M’s Managing Director, Anthony J. Bolzan, who along with Human Resource Manager Maria Theresa Chiongbian, presented Yuseco with a supposed agreement accepting his request for a separation package effective January 1, 2016. Yuseco was shocked by the resignation announcement which was communicated via company-wide email, and he refused to sign the waiver and quitclaim presented by the company. Following a formal notice explaining that his position was deemed redundant, Yuseco demanded a termination pay equivalent to what he would hav

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Facts:

Background and Employment

• Lauro D. Yuseco served as Country Business Leader (CBL) of 3M Philippines, Inc. since 1997 and earned a monthly salary of P271,000.00.
• The company, a subsidiary of the American multinational 3M, had organized its marketing and sales operations by business groups headed by Country Business Leaders.
• In 2015, 3M Philippines shifted from a “Business Group” model to a “Market Focused” organization in line with business strategies employed by other 3M subsidiaries in Southeast Asia.

The Events Leading to Termination

• On November 25, 2015, respondent was called by Managing Director Anthony J. Bolzan to a meeting in which he was accompanied by Human Resource Manager Maria Theresa Chiongbian.
• During the meeting, respondent was presented with an agreement and accompanying documents (including a waiver and quitclaim) purporting to accept his request for a separation package.
• Respondent refused to sign, after which Bolzan instructed him not to report for work any longer.
• Later that day, an email was sent companywide by Bolzan, announcing that respondent would be “pursuing other opportunities,” an announcement that embarrassed and humiliated him before his colleagues, friends, clients, and relatives.
• On December 1, 2015, respondent received a formal Notice of Separation from the Human Resource Department stating that his position as Country Business Leader had been declared redundant, effective January 1, 2016.
• During a subsequent meeting, respondent was offered a special separation package encompassing:
• Separation pay exceeding statutory requirements (P5,173,825.21).
• Additional benefits such as a retirement plan contribution, an extra payout for long service, two years’ health coverage extension, and two years’ worth of life insurance.
• Text messages exchanged between respondent and Chiongbian reflected that respondent sought clarifications regarding tax implications and the clearance process.
• Although initially accepting the company’s practice of announcing separations via email—with the understanding that he could personally inform his team—respondent later repudiated the acceptance of the package and refused to undergo the clearance process.

Legal Proceedings and Contested Positions

• Respondent filed a complaint for illegal dismissal, non-payment of benefits, and damages against 3M Philippines, Inc.
• At the Labor Arbiter level:
• Labor Arbiter Pablo A. Gajardo, Jr. ruled in favor of respondent, declaring his dismissal illegal.
• The award included separation pay, full backwages, moral and exemplary damages, along with attorney’s fees.
• The Labor Arbiter found that petitioner’s redundancy program was arbitrary, demonstrated by inconsistent letters and a seemingly afterthought rationale.
• The NLRC reversed the Labor Arbiter’s decision by finding that:
• The reorganization was based on sound business considerations.
• The criteria for determining redundancy (work experience, performance ratings, etc.) were fair and supported the decision to retain Tommee Lopez over respondent.
• Procedural requirements for notice and separation pay were met.
• In the Court of Appeals:
• The CA reversed the NLRC ruling, declaring respondent’s dismissal as illegal.
• The CA found that the evidence, including the two letters (dated November 25 and December 1, 2015), were contradictory and indicative of bad faith.
• In its petition for review on certiorari, petitioner 3M Philippines, Inc. sought to reverse and set aside the CA’s decision, reiterating that:
• The redundancy program was valid.
• The allegedly divergent letters were complementary when read in context.
• The documentary evidence and affidavits (including multiple affidavits of HR personnel) sufficiently proved the existence and proper implementation of the redundancy program.

Reorganization and its Rationale

• The company restructured by merging the Industrial Business Group with the Safety & Graphics Business Group to create the Industrial & Safety Market Center.
• This reorganization was intended to improve operational efficiency, enhance marketing and sales capability, and align with international practices of 3M subsidiaries.
• In the process, the decision-making involved a comparative evaluation of respondent and Lopez based on:
• Breadth of work experience (respondent limited to Industrial operations versus Lopez with wider experience spanning both divisions).
• Recent performance ratings over the last three years.

Documentary Evidence and Compliance with Procedure

• Petitioner produced various documents to support its redundancy claim:
• A letter dated November 25, 2015, informing respondent of the impending redundancy and associated separation package.
• A formal Notice of Separation on December 1, 2015, which served as proper written notice to both respondent and the DOLE.
• Text message exchanges between Chiongbian and respondent, confirming that respondent was informed about his impending termination.
• A drafted Release, Waiver and Quitclaim document for discussion at the November 25, 2015 meeting.
• The company complied with the notice requirement stipulated under the Labor Code by serving a written notice at least 30 days before the termination became effective.

Issue:

Whether the termination of respondent’s employment was legally valid on the ground of redundancy.

• Did petitioner comply with the substantive and procedural requisites under the Labor Code regarding redundancy?
• Are the allegedly inconsistent communications (the November 25 and December 1, 2015 letters) indicative of an illegal dismissal, or do they support a valid redundancy program?
• Was the criteria used by petitioner (comparing respondent’s work experience and performance ratings with those of Lopez) fair, reasonable, and in good faith?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)