G.R. No. L-51607 - Acda vs. Minister of Labor

Petitioner received his appointment dated 26 September 1976 as Sales Supervisor Trainee, but was required to start work on 1 September 1976 to meet an urgent need.

His employment was for a temporary period of one (1) month, with the understanding that satisfactory performance during this period would lead to a probationary appointment and eventual regularization.

Effective 31 January 1977 or during the probationary period, petitioner was dismissed by respondent company on the grounds of “loss of confidence” and alleged inadequacy in capabilities as Regional Sales Supervisor.

Petitioner challenged his dismissal by filing a complaint with the Ministry of Labor on 28 February 1977, claiming that:

He was denied due process—he was not informed of his shortcomings beforehand and was not given an opportunity to respond or correct alleged mistakes.

The charge of “loss of confidence” was baseless in the absence of any standard of performance or clear objective criteria, rendering the dismissal an abuse of managerial prerogative aimed at circumventing the law on security of tenure.

The Labor Arbiter rendered a decision on 23 August 1977 in favor of petitioner by finding that:

Evidence, such as the incident involving a car memorandum issued by Mr. Perez and subsequent favorable action by the company president, pointed to internal office conflicts or petty jealousy rather than performance issues.

A letter from the company president dated 3 January 1977 congratulated petitioner for his “excellent job performance,” further reinforcing his competent record.

The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision in its resolution dated 19 January 1978, despite noting procedural irregularities in the filing of the appeal by the respondent company (e.g., improper number of copies and non-payment of the appeal fee).

Respondent company, not satisfied with the NLRC resolution, appealed to the Minister of Labor.

An Order dated 11 May 1979 by the Deputy Minister (acting by authority of the Minister) reversed the NLRC decision, holding that the dismissal was valid based on the probationary nature of petitioner’s employment and the employer’s prerogative to terminate if performance was deemed unsatisfactory.

The appeal was not perfected in compliance with the statutory and reglementary requirements, particularly noting the non-payment of the appeal fee which is a jurisdictional requirement.

The decision of the Minister of Labor lacked proper jurisdiction because of these procedural lapses.

It is emphasized that perfection of an appeal in labor cases must be done within the prescribed period and in strict adherence to technical requirements, such as the payment of the appeal fee and submission of the required number of copies.

Non-compliance with these requirements renders the appeal not duly perfected, thereby causing the prior decision (which found in petitioner’s favor) to become final and executory.

Whether the dismissal of the petitioner, a probationary employee, was justified based on the asserted “loss of confidence” and alleged inadequacies.
Whether the procedural requirements for perfecting an appeal in labor cases—particularly the payment of the appeal fee and proper submission of documents—are jurisdictional in nature, and whether the respondent company’s failure to comply with these requirements renders the appeal null.
Whether the favorable findings of the Labor Arbiter and the NLRC regarding the absence of just cause for dismissal should prevail despite the respondent company's argument on the managerial prerogative inherent in terminating a probationary employee.