Case Digest (G.R. No. 192571)
Facts:
Abbott Laboratories, Philippines, Cecille A. Terrible, Edwin D. Feist, Maria Olivia T. Yabut‑Misa, Teresita C. Bernardo, and Allan G. Almazar v. Pearlie Ann F. Alcaraz, G.R. No. 192571, April 22, 2014, the Supreme Court En Banc, Perlas‑Bernabe, J., writing for the Court.Petitioners are Abbott Laboratories, Philippines and several company officers; respondent is Pearlie Ann F. Alcaraz, a former Regulatory Affairs Manager employed by Abbott on a probationary basis. Prior to her dismissal Abbott published a job vacancy (June 27, 2004); Alcaraz applied (October 4, 2004); Abbott’s December 7, 2004 offer sheet and her February 12, 2005 employment contract expressly stated a six‑month probationary status (Feb. 15 to Aug. 14, 2005). On hiring Alcaraz received her job description, Abbott’s organizational chart, underwent pre‑employment orientation and training, and later received the Code of Good Corporate Conduct and Probationary Performance Standards and Evaluation (PPSE) modules; she also acknowledged Abbott’s single evaluation system for employees. Abbott terminated Alcaraz during the probationary period citing inadequate performance (poor time management, inability to gain staff trust, failure to train staff, and lack of required judgment on case processing and article review).
At the administrative level, the Labor Arbiter (LA) rendered findings (described in the records) which were reviewed by the National Labor Relations Commission (NLRC). The NLRC ruled in favor of Alcaraz (concluding her dismissal was illegal because she was a regular employee), a ruling that the Court of Appeals (CA), acting on a Rule 65 certiorari petition, upheld by denying Abbott’s petition and finding no grave abuse of discretion on the part of the NLRC. Abbott then filed a Rule 45 petition for review on certiorari to the Supreme Court. In its July 23, 2013 Decision the Court reversed the CA and NLRC, finding that the NLRC committed grave abuse of discretion and that Alcaraz was a probationary employee who had been apprised of her duties and responsibilities; the Court nevertheless recognized Abbott’s breach of its internal procedures and order...(Subscriber-Only)
Issues:
- Did the Supreme Court exceed the scope of a Rule 45 review by re‑weighing evidence and effectively conducting a factual re‑examination of the CA/ NLRC findings?
- Was respondent Pearlie Ann Alcaraz a probationary employee who had been duly informed of the standards for regularization such that her dismissal for inadequate performance was justified?
- Does an employer’s failure to follow its own internal evaluation procedure negate a valid cause for termi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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