Case Digest (G.R. No. 214291)
Facts:
The case involves Jason Yu Lim as the respondent and American Power Conversion Corporation (APCC), American Power Conversion Singapore Pte. Ltd., American Power Conversion (A.P.C.), B.V., American Power Conversion (Phils.) B.V., and several individuals including David W. Plumer, Jr., George Kong, and Alicia Hendy as petitioners. Jason Yu Lim was hired on July 1, 1998, as the Country Manager for the American Power Conversion Philippine Sales Office, which was not registered with the Securities and Exchange Commission (SEC). This office acted as a liaison for APCC, providing sales and marketing support in the Philippines. In 2002, American Power Conversion (Phils.) B.V. (APCP BV) was established and acquired the operations of the unregistered Philippine Sales Office. Lim was promoted to Regional Manager for APC North ASEAN in November 2004, overseeing sales and marketing operations across several countries.
In 2005, Lim and another manager, David Shao, reported irregularities...
Case Digest (G.R. No. 214291)
Facts:
Employment Context
- Jason Yu Lim (respondent) was hired on July 1, 1998, as Country Manager of American Power Conversion Philippine Sales Office, an unregistered entity functioning as a liaison office for American Power Conversion Corporation (APCC), an American corporation.
- APCC is involved in designing, developing, manufacturing, and marketing power protection and management solutions.
- Lim was included in the payroll of American Power Conversion (Phils.), Inc. (APCPI), the only SEC-registered entity in the Philippines at the time.
Promotion and Reporting Structure
- In November 2004, Lim was promoted to Regional Manager for APC North ASEAN, reporting directly to Larry Truong, Country General Manager for APC ASEAN.
- In 2005, Truong was replaced by George Kong.
Allegations of Irregularities and Termination
- Lim and David Shao (another regional manager) reported alleged irregularities committed by Kong to higher management.
- Kong expressed displeasure via email, and Shao was terminated without cause on September 30, 2005.
- On October 17, 2005, Kong informed Lim that his position was declared redundant due to company restructuring.
- Lim received a termination letter dated October 17, 2005, stating his last working day would be November 17, 2005.
Legal Proceedings
- Lim filed a labor case for illegal dismissal, claiming the redundancy program was a sham, and his termination was retaliatory.
- The Labor Arbiter ruled in Lim’s favor, finding his dismissal illegal due to lack of evidence supporting redundancy and failure to notify the DOLE.
- The National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision, finding the dismissal valid due to redundancy.
- The Court of Appeals (CA) reinstated the Labor Arbiter’s decision, ruling that the redundancy program was not substantiated and the dismissal was illegal.
Issue:
- Whether the Court of Appeals erred in exercising its certiorari jurisdiction without finding grave abuse of discretion by the NLRC.
- Whether the NLRC’s finding that Lim was validly dismissed due to redundancy was correct.
- Whether the redundancy program was justified and complied with legal requirements.
- Whether the petitioners complied with the notice requirement under the Labor Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)