Title
Arrieta vs. National Labor Relations Commission
Case
G.R. No. 126230
Decision Date
Sep 18, 1997
Employee reassigned after reorganization; claims constructive dismissal due to rank and salary grade changes. Court upheld reorganization as valid management prerogative, finding no demotion or pay reduction. Petition dismissed.
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Case Digest (G.R. No. 126230)

Facts:

  1. Employment History

    • Petitioner Carmen Arrieta began working for Central Negros Electric Cooperative, Inc. (CENECO) on January 16, 1988, as Executive Secretary to the President and the Board of Directors, with a grade of 7-B and a monthly salary of P2,360.00.
    • On April 16, 1988, she was appointed as Executive Secretary to the Board of Directors under Grade 9 and Rank 9-B, with a basic salary of P3,325.00.
    • On August 28, 1989, she was detailed to the Engineering Department as its Secretary while retaining her status as Executive Secretary.
    • On April 19, 1991, she was upgraded to Rank 9-1, receiving a monthly salary of P4,947.00.
  2. Reorganization of CENECO

    • On December 18, 1991, CENECO’s Board of Directors passed Resolution No. 5446, abolishing all positions in the 1987 plantilla and adopting a new plantilla proposed by the Steering Committee for Reorganization.
    • The reorganization aimed to streamline operations and assign employees based on qualifications, aptitude, and competence.
    • Under the new plantilla, the position of Executive Secretary to the Board of Directors was abolished, replaced by a Secretary/Stenographer (Grade 7-9) and an Assistant Secretary (Grade 5-5).
    • Petitioner was permanently appointed as Secretary in the Engineering Department with a grade of 6-5 but retained her monthly salary of P4,947.00. She signed the appointment under protest.
  3. Petitioner’s Complaints

    • On January 24, 1992, petitioner demanded restoration to her former position as Executive Secretary with a rank of 9-1 and a salary of P3,325.00.
    • She filed a complaint for constructive dismissal, alleging a reduction in her basic salary (from P3,325.00 to P3,243.80) and a demotion in rank and grade (from 9-1 to 6-5).
    • She claimed her new position was demeaning and that the reorganization was a ploy to remove her as Executive Secretary.
  4. Labor Arbiter and NLRC Decisions

    • The Labor Arbiter ruled in favor of petitioner, finding constructive dismissal and ordering her reinstatement to her former position or a substantially equivalent one, with salary differentials, moral and exemplary damages, and attorney’s fees.
    • The National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision, dismissing the complaint and finding no constructive dismissal.

Issue:

  1. Whether the reorganization of CENECO and petitioner’s reassignment constituted constructive dismissal.
  2. Whether petitioner’s reduction in rank and salary grade amounted to a demotion.
  3. Whether petitioner’s security of tenure was violated by the reorganization.
  4. Whether the reorganization was a valid exercise of management prerogative.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court ruled that the reorganization of CENECO was a valid exercise of management prerogative, and petitioner’s reassignment did not constitute constructive dismissal. Her claims of demotion and salary reduction were unfounded, and her security of tenure was not violated. The petition was dismissed, and the NLRC’s decision was affirmed.


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