Case Digest (G.R. No. 192571) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Abbott Laboratories, Philippines, et al. v. Pearlie Ann F. Alcaraz, petitioners Abbott Laboratories, Philippines; Cecille A. Terrible; Edwin D. Feist; Maria Olivia T. Yabut-Misa; Teresita C. Bernardo; and Allan G. Almazar sought review of the Court of Appeals’ affirmation of the National Labor Relations Commission’s (NLRC) ruling that respondent Pearlie Ann F. Alcaraz had been illegally dismissed as a regular employee. On June 27, 2004 Abbott advertised for a Regulatory Affairs Manager, outlining the duties and responsibilities. Alcaraz applied on October 4, 2004 and received an offer sheet on December 7, 2004 stating her probationary status. She signed a six-month probationary contract on February 12, 2005 (February 15 to August 14, 2005). During orientation, she received Abbott’s organizational chart, job description, Code of Conduct, Performance Modules and training schedule, with explanations of the evaluation system. Despite her prior pharmaceutical experience, Abbott te Case Digest (G.R. No. 192571) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- Abbott Laboratories, Philippines, et al. (“Abbott”) filed a petition for certiorari under Rule 65 before the Court of Appeals (CA) challenging an NLRC decision that treated Pearlie Ann F. Alcaraz (“Alcaraz”) as a regular employee illegally dismissed.
- The CA denied the petition, finding no grave abuse of discretion by the NLRC. Abbott elevated the case to the Supreme Court via a Rule 45 petition for review on certiorari.
- On July 23, 2013, the Supreme Court rendered a Decision reversing the CA, ruling that Alcaraz was a probationary employee properly dismissed for failure to qualify as a regular employee.
- Alcaraz filed a motion for reconsideration dated August 23, 2013, which prompted the April 22, 2014 Resolution now under review.
- Employment and Probationary Arrangement
- Abbott published a job opening for Regulatory Affairs Manager on June 27, 2004; Alcaraz applied on October 4, 2004.
- Abbott’s December 7, 2004 offer letter and the February 12, 2005 employment contract expressly stated a six-month probationary period from February 15 to August 14, 2005.
- Prior to and upon engagement, Abbott provided Alcaraz with:
- A detailed job description and organizational chart via e-mail.
- Abbott’s Code of Conduct, Performance Modules, and orientation on office policies and reporting lines.
- A training program and pre-employment orientation explaining performance evaluation procedures.
- Alcaraz had prior pharmaceutical industry experience and admitted extensive relevant training.
- Events Leading to Dismissal
- On April 20, 2005, Alcaraz learned in a meeting that Abbott questioned her work through a separate inquiry process not typical for probationary reviews.
- On May 19, 2005, Abbott issued a written notice citing “Not Achieved” ratings in core competencies, immediately terminating her employment for failure to qualify as a regular employee.
- Alcaraz maintained she was unaware of specific performance standards at engagement and thus could not have failed to meet them.
Issues:
- Did the Supreme Court exceed its scope of review under Rule 45 by re-weighing evidence in a case originating from a CA Rule 65 petition?
- Were reasonable performance standards made known to Alcaraz at the time of her engagement as required for valid probationary employment?
- If Abbott failed to comply with probationary-employment requirements, was Alcaraz a regular employee entitled to reinstatement and backwages?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)