Aguilera vs. Coca-Cola FEMSA Philippines, Inc.

G.R. No. 238941
Employee dismissed for redundancy; Supreme Court ruled termination illegal due to bad faith, invalid quitclaim, and failure to meet redundancy criteria.
dismissal redundancy reinstatement

Case Digest (G.R. No. 238941)

Facts:

Bernilo M. Aguilera v. Coca‑Cola FEMSA Philippines, Inc., G.R. No. 238941, September 29, 2021, Supreme Court First Division, Lazaro‑Javier, J., writing for the Court.

Petitioner Bernilo M. Aguilera was employed by respondent Coca‑Cola FEMSA Philippines, Inc. (CCFPI) since July 1, 1995 in various capacities (Refrigeration Technician, Trade Asset Controller, Maintenance Coordinator) and most recently as Cold Drink Associate supervising third‑party service providers for the company’s electric coolers. In May 2013 new management restructured operations; on August 6, 2013 Aguilera was informed he “failed the assessment” (results undisclosed) and was served a notice that his position was abolished for redundancy, effective September 6, 2013. He accepted a separation package and executed a Deed of Receipt, Waiver and Quitclaim on September 11, 2013.

CCFPI maintained it acted in good faith: it submitted an Employment Termination Report to DOLE, paid separation benefits exceeding statutory minimums, and presented an HR affidavit explaining deliberations and criteria (performance ratings, background, salary, location) used in staffing the new structure; it belatedly produced a psychometric test result showing a low IQ score for petitioner. Aguilera countered that CCFPI merely relabeled and split his former position and then filled substantially similar roles with new hires at lower pay, that the company failed to apply fair and reasonable selection criteria, and that he was compelled by circumstances to sign the quitclaim.

At the labor tribunal level, Labor Arbiter Melchisedek A. Guan (Decision, Sept. 30, 2014) found the dismissal illegal, ordered reinstatement and awarded partial backwages, moral and exemplary damages, and attorney’s fees. The National Labor Relations Commission affirmed with modification (Decision, June 30, 2016): it deleted moral and exemplary damages but granted attorney’s fees; a partial motion for reconsideration was denied (Resolution, Sept. 26, 2016). CCFPI filed a petition for certiorari to the Court of Appeals. The Court of Appeals, in a Decision penned by Associate Justice Manuel M. Barrios (Oct. 20, 2017), reversed the labor tribunals, holding CCFPI complied with redundancy requisites, acted in good faith, used fair and reasonable criteria, and that pet...(Pro-only)

Issues:

  • Was petitioner validly dismissed on the ground of redundancy? ...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)
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