Facts:

The case centers on a Petition for Review on Certiorari filed by Armando Aliling (petitioner) against Wide Wide World Express Corporation (WWWEC) and its officers: Jose B. Feliciano, Manuel F. San Mateo III, and Joseph R. Lariosa (respondents). The petition challenges the decisions of the Court of Appeals (CA) issued on July 3, 2008, and the subsequent resolution on December 15, 2008, which modified earlier resolutions by the National Labor Relations Commission (NLRC). These latter resolutions affirmed a labor arbiter's decision dated April 25, 2006, which determined that Aliling's termination was unjustified.

Aliling was offered employment on June 2, 2004, by WWWEC as an Account Executive for Seafreight Sales, at a monthly salary of PhP 13,000, along with various allowances, conditional upon a six-month probationary period. Upon signing the employment contract on June 11, 2004, conditions for regularization were not explicitly defined, although the contract indicated th

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Facts:

Employment Agreement and Initial Engagement

• On June 2, 2004, WWWEC issued a letter offering Armando Aliling a position as Account Executive (Seafreight Sales) with a compensation package including a monthly salary of PhP 13,000, various allowances, and the possibility of a 14th month pay subject to company profitability.
• The offer required a six‐month probationary period with the express condition that performance during this period would determine his confirmation as a regular employee.
• On June 11, 2004, Aliling and WWWEC formalized their relationship through an employment contract detailing that conversion to regular status was contingent on work performance and that his employment could be terminated for just cause or per terms agreed at the onset.

Change in Assignment and Performance Issues

• Shortly after the engagement, rather than continuing in Seafreight Sales, Aliling was reassigned to handle the newly launched domestic cargo forwarding service called Ground Express (GX), starting June 18, 2004.
• The change in assignment involved marketing and acquiring daily contracts for GX, a task distinct from his original job requirements.
• Manuel F. San Mateo III, the Sales and Marketing Director of WWWEC, communicated via email (barely a month after assignment) his dissatisfaction with Aliling’s performance, setting an 80% full quota for GX shuttles to be met by August 5, 2004.

Attendance and Resignation Issues

• On September 25, 2004, Joseph R. Lariosa, HR Manager of WWWEC, requested Aliling to explain his alleged absence without leave for September 20, 2004; Aliling responded two days later, denying the absence and attaching his timesheet for September 20–24, 2004.
• Aliling raised an issue regarding the withholding of his salary for the period from September 11 to 25, 2004.
• On September 27, 2004, Aliling tendered his resignation effective October 15, 2004, based on instructions allegedly given by San Mateo, although WWWEC took no immediate action on his tender.

Filing of Complaint and Subsequent Actions

• Despite tendering his resignation, Aliling demanded reinstatement and a written apology, alleging that San Mateo had forced him to resign.
• On October 4, 2004, Aliling filed a complaint before the NLRC for illegal dismissal, nonpayment of salaries, and damages. His affidavit claimed that at the time of his engagement, he had not been informed of any specific performance standards necessary for regularization.
• WWWEC, in its defense, submitted a position paper including a letter of appointment and a memo (dated September 20, 2004) which purported to set performance targets. Aliling, however, denied receiving such memo.

Decisions in Lower Courts

• The Labor Arbiter issued a decision on April 25, 2006, declaring Aliling’s termination as unjustified, awarding him backwages (computed based on PhP 17,300 per month), prorated 13th month pay, and attorney’s fees.
• The NLRC affirmed the Labor Arbiter’s decision in its resolutions dated May 31, 2007, and August 31, 2007, denying motions for reconsideration.
• The Court of Appeals (CA) modified the NLRC’s award in its decision, declaring that:
• Aliling was to be deemed a regular employee from the date of his contract on June 11, 2004, since he was not advised of the reasonable standards of performance at the time of engagement.
• The CA ordered WWWEC to pay a total money judgment, attorney’s fees, and additionally, separation pay equivalent to one-half month’s salary for the relevant period.

Further Proceedings and Points of Controversy

• On December 15, 2008, the CA rejected Aliling’s motion for reconsideration regarding its previous order.
• The petition for review on certiorari raised issues including the failure to reinstate Aliling, the non-award of backwages, and the denial of moral and exemplary damages.
• The dispute also centered on whether the standards for regularization had been properly communicated and whether the termination process adhered to due process.

Issue:

• Whether the failure of the Court of Appeals to order reinstatement, despite finding that Aliling was illegally dismissed, was contrary to law and jurisprudence.
• Whether the non-award of backwages, in the absence of a reinstatement order, violates legal provisions and established case law.
• Whether the denial of moral and exemplary damages—despite the finding that Aliling was terminated in a manner intended to prevent his regularization—was legally erroneous.
• Whether the employer’s actions, in not informing Aliling of the reasonable performance standards at the time of his engagement, effectively converted his status from probationary to regular employee.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)