G.R. No. L-76959 - Abbott Laboratories , Inc. vs. National Labor Relations Commission

Complainant Albert Bobadilla began his employment with Abbott Laboratories in May 1982.
Following training, in September 1982, he was designated as a Professional Medical Representative (PMR) and assigned to cover parts of Metro Manila, including Sta. Cruz, Binondo, and portions of Quiapo and Divisoria.
As a condition of his employment, Bobadilla agreed:

To accept assignments in any province or city in the Philippines.
To relocate and live in the territory assigned.
That any misrepresentation in his application could result in immediate dismissal if employed.

Abbott Laboratories maintained a company policy of periodically reassigning or transferring its sales personnel in accordance with operational demands.
The policy was clearly communicated to all sales applicants and employees, reinforcing the expectation that employees must be willing to work anywhere in the Philippines.

On July 22, 1983, Jaime C. Victa, a company official, informed Bobadilla of his transfer effective August 1, 1983, to the newly opened Cagayan territory (covering Cagayan, Nueva Vizcaya, and Isabela).
A formal memorandum dated July 29, 1983, documented the transfer order.
The selection of Bobadilla for the new territory was based on his reputation as a veteran and seasoned PMR capable of operating with minimal supervision.
On August 1, 1983, Bobadilla, through his lawyer, sent a letter objecting to the transfer, alleging that the order was tantamount to a demotion and was personal and punitive in nature.
An inter-office correspondence on August 8, 1983, from Victa warned Bobadilla to comply with the transfer order by August 15, 1983, or face removal from the payroll.
Instead of reporting for duty or substantiating his objections, Bobadilla filed leave applications from August 2 to 9 and August 10 to 13, 1983, and eventually filed the present complaint on August 18, 1983.

The Labor Arbiter initially ruled in favor of Abbott Laboratories on the ground that Bobadilla was guilty of gross insubordination for refusing to obey the lawful transfer order.
The National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision, finding that there was no valid or justifiable reason for Bobadilla’s dismissal and ordering his reinstatement with full backwages.
Subsequent motions for reconsideration by the petitioners were ultimately unsuccessful, and the case was elevated to the Supreme Court via a petition for review on certiorari.

Was Abbott Laboratories justified in transferring Bobadilla to a new territory in line with its established employment policies?
Did Bobadilla’s refusal to accept the transfer constitute gross insubordination warranting dismissal?

Was the transfer a legitimate operational decision consistent with the conditions of employment, or was it a demotion with personal and punitive motives?
Does the employee’s prior consent to be assigned anywhere in the Philippines negate any claims of an unlawful change in his employment terms?

To what extent does the inherent right of management to control employment matters, including transfers, apply when an employee has willingly accepted conditions involving mobility?
Does the law permit the dismissal of an employee for failing to comply with a transfer that is executed in good faith and in line with the company’s operational demands?