Case Digest (G.R. No. 228088)
Facts:
The case involves Automatic Appliances, Inc. (AAI) and its management, represented by petitioners Samson F. Lim, Cornelio P. Buenaventura, and Christine M. Pontillas, against respondent Francia B. Deguidoy. Deguidoy was hired as a regular Sales Coordinator at AAI's Cubao Branch on June 3, 1998. In 2013, AAI faced economic difficulties, leading to a decline in sales and the closure of some branches. On July 1, 2013, AAI issued a memorandum announcing a re-assignment of employees, which included transferring Deguidoy from the Cubao Branch to the Tutuban Branch, a move she accepted. However, while at the Tutuban Branch, Deguidoy struggled to meet her sales quota and incurred 29 days of unexplained absences from March to August 2013.
On June 14, 2013, AAI management urged her to undergo counseling to improve her performance, to which she attributed her struggles to weight gain. AAI offered her a lateral transfer to a position that would require less physical strain, but sh...
Case Digest (G.R. No. 228088)
Facts:
Employment and Initial Assignment:
- Francia B. Deguidoy (Deguidoy) was hired by Automatic Appliances, Inc. (AAI) on June 3, 1998, as a regular Sales Coordinator at its Cubao Branch. Her role involved selling merchandise and maintaining a branch sales quota.
Company Financial Difficulties and Reassignment:
- In 2013, AAI faced economic difficulties and declining sales, leading to cost-cutting measures, including the closure of some branches. On July 1, 2013, AAI issued a memorandum informing employees of their reassignment to various branches. Deguidoy was reassigned from the Cubao branch to the Tutuban Branch, which she accepted.
Performance Issues at Tutuban Branch:
- At the Tutuban Branch, Deguidoy failed to meet her sales quota and incurred 29 days of unexplained absences from March to August 2013. Her sales performance declined, while her colleagues surpassed their quotas.
- On June 14, 2013, AAI urged Deguidoy to undergo counseling to improve her performance. During the session, Deguidoy attributed her poor performance to weight gain, which made it difficult for her to stand and perform her tasks. AAI suggested a lateral transfer to a receptionist or invoicing clerk role, but Deguidoy refused.
Suspension and Intended Transfer:
- On August 2, 2013, the Tutuban Branch Manager, Cristine M. Pontillas, reported Deguidoy’s poor performance to AAI. AAI reviewed her records and issued Attendance Infraction Memos and an Inefficiency and Gross Negligence Memo on August 27, 2013, resulting in a one-month suspension. Deguidoy accepted the suspension and apologized.
- On October 7, 2013, Deguidoy returned to work but was verbally informed of an intended transfer to the Ortigas branch. Dismayed, she left during her lunch break and never returned.
Legal Proceedings:
- On October 14, 2013, Deguidoy filed a case for illegal dismissal with money claims, including 13th month pay.
- The Labor Arbiter (LA) dismissed her complaint, ruling that she was not terminated but was being transferred. However, the LA ordered AAI to pay proportionate 13th month pay.
- The National Labor Relations Commission (NLRC) reversed the LA’s decision, finding Deguidoy constructively dismissed and ordering AAI to pay backwages and separation pay.
- The Court of Appeals (CA) affirmed the NLRC’s ruling but modified the award, ordering Deguidoy’s reinstatement and payment of backwages from October 7, 2013, until her actual reinstatement.
Issue:
- Whether Deguidoy was constructively dismissed by AAI.
- Whether AAI’s decision to transfer Deguidoy was a valid exercise of management prerogative.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court reversed the CA’s decision, ruling that Deguidoy was not constructively dismissed. AAI’s transfer decision was a valid exercise of management prerogative, and Deguidoy was ordered to return to work. AAI was also ordered to pay her proportionate 13th month pay for 2013.