G.R. No. 192571 - Abbott Laboratories, Philippines vs. Alcaraz

On June 27, 2004, Abbott Laboratories, Philippines (Abbott) published a vacancy for a Medical and Regulatory Affairs Manager.
Pearlie Ann F. Alcaraz, then Regulatory Affairs and Information Manager at another firm, applied on October 4, 2004.
Abbott offered her the position on probationary status on December 7, 2004; she accepted the same day.
An employment contract was signed on February 12, 2005, stipulating a six-month probationary period (February 15–August 14, 2005) with a P110,000 monthly salary.

Upon engagement, Alcaraz received Abbott’s organizational chart, job description, Code of Good Corporate Conduct, and performance modules.
In a pre-employment orientation, she was briefed on her duties, staff management, reporting lines (to Kelly Walsh and Allan Almazar), and operational policies.
Abbott’s Probationary Performance Standards and Evaluation (PPSE) procedure required formal reviews at the third and fifth months, plus a Performance Improvement Plan if gaps arose; signed PPSE forms were to be filed with HR.

Alcaraz cautioned her staff for dress-code violations, moonlighting, and insubordination; Walsh considered her approach “too strict.”
On May 16, 2005, Walsh and HR Director Cecille C. Terrible informed her she failed to meet regularization standards and demanded her resignation.
Pressured, barred from the office, and stripped of ID badges, she was handed a termination letter dated May 19, 2005, citing poor time management, rapport, training, and judgment.
Personal belongings were allegedly removed; on May 23 and 27, 2005, she formally received the termination notice.

Alcaraz filed for illegal dismissal before the Labor Arbiter (LA); LA dismissed her complaint on March 30, 2006.
On appeal, the NLRC reversed (Sept 15, 2006), finding illegal dismissal; ordered reinstatement, backwages (P1,760,000), moral (P50,000), exemplary (P50,000) damages, and 10% attorney’s fees.
Abbott’s certiorari petitions to the Court of Appeals (CA) were denied (Decision Dec 10, 2009; Resolution June 9, 2010); a second CA petition on execution likewise denied (May 18, 2010).
Abbott filed a Rule 45 petition for review on certiorari with the Supreme Court, raising forum-shopping, certification, probationary standards, validity of dismissal, and individual liability.

Whether petitioners committed forum shopping or violated the certification requirement under Section 5, Rule 7, Rules of Court.
Whether Alcaraz was sufficiently informed of reasonable standards for her regularization at the time of engagement.
Whether the termination of Alcaraz’s employment was valid under the Labor Code’s probationary employment and due-process requirements.
Whether individual corporate officers are personally liable for Alcaraz’s dismissal and entitled damages.