Title
Agustin vs. Alphaland Corporation
Case
G.R. No. 218282
Decision Date
Sep 9, 2020
Agustin, hired as Executive Chef, was terminated during probation. Alphaland failed to specify employment standards, rendering his dismissal illegal. SC awarded backwages, separation pay, and legal interest.
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Case Digest (G.R. No. 218282)

Facts:

Employment Offer and Probationary Period

  • On July 6, 2011, Alphaland Corporation offered Redentor Y. Agustin the position of Executive Chef with a gross monthly salary of P122,500.00. The offer included a six-month probationary period. Agustin accepted the offer by signing the letter.

Responsibilities as Executive Chef

  • Agustin took over the Balesin Island Club's Kitchen, organized the kitchen, prepared job descriptions for kitchen staff, conceptualized the menu, designed the kitchen layout, and managed equipment acquisition.

Termination

  • On November 4, 2011, barely four months into his employment, Agustin received a Notice of Termination. Alphaland stated that Agustin failed to meet the company's standards for regular employment, and his termination was effective immediately.

Complaint for Illegal Dismissal

  • Agustin filed a complaint for illegal dismissal, alleging that the standards for regular employment were not made known to him at the time of his engagement. He sought reinstatement, backwages, 13th month pay, damages, and attorney's fees.

Alphaland's Defense

  • Alphaland claimed that Agustin's performance was assessed by executives and business associates, who found his cooking skills unsatisfactory for a high-end luxury resort. They argued that Agustin failed to meet the standards of rendering "the highest quality of professional service" and "always pursuing the interest of the company."

Issue:

  1. Whether Agustin was illegally dismissed.
  2. Whether Alphaland informed Agustin of the reasonable standards for his probationary employment.
  3. Whether Agustin is entitled to reinstatement, backwages, and other benefits.
  4. Whether the procedural and substantive due process requirements for dismissal were observed.

Ruling:

  • The Supreme Court ruled that Agustin was a regular employee from the start of his employment, as Alphaland failed to specify reasonable standards for his probationary employment. Consequently, his dismissal was illegal.
  • Agustin is entitled to backwages from the date of his illegal dismissal (November 4, 2011) until the finality of the decision. However, due to strained relations, separation pay was awarded in lieu of reinstatement.
  • The Court affirmed the lower courts' decisions but modified the awards to include additional backwages and separation pay.

Ratio:

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