Case Digest (G.R. No. 129843)
Facts:
The case involves Blue Dairy Corporation and its officials Edison T. Aviguetero and Pedro G. Miguel as petitioners, and Elvira R. Recalde as the respondent. Recalde was hired by Blue Dairy Corporation on May 14, 1994, as a food technologist responsible for various laboratory functions, including microanalysis, physical and chemical analysis, and product development. On May 22, 1994, she reported for work on a Sunday but claimed she was not compensated with premium pay. On October 21, 1994, while accompanying the Production Manager, Editha N. Nicolas, to evaluate a product, their vehicle was damaged due to a falling post during a typhoon. Subsequently, on December 3, 1994, Recalde was transferred from her laboratory position to the vegetable processing section, where she performed menial tasks such as coring lettuce and mincing garlic, which she found humiliating. On December 14, 1994, she ceased reporting for work and sent a letter to Aviguetero stating her resignation due to...
Case Digest (G.R. No. 129843)
Facts:
Employment and Duties
- Blue Dairy Corporation, engaged in processing dairy and chocolate products, hired Elvira R. Recalde as a food technologist on May 14, 1994. Her duties included microanalysis, physical and chemical analysis, supervision, and product development in the laboratory.
Incident on May 22, 1994
- Recalde reported for work on a Sunday (May 22, 1994) but claimed she was not given her premium pay.
Incident on October 21, 1994
- Recalde accompanied Production Manager Editha N. Nicolas for a sensory evaluation of vanilla syrup at a client’s outlet. On their way back, a post fell on the company vehicle due to a typhoon, damaging the windshield and side mirror.
Transfer to Vegetable Processing Section
- On December 3, 1994, Recalde was transferred from the laboratory to the vegetable processing section, where she performed tasks like coring lettuce and repacking garlic. She found the new role humiliating and menial.
Resignation and Complaint
- On December 14, 1994, Recalde stopped reporting for work and sent a letter to the company president, Edison T. Aviguetero, stating her decision to resign due to "drastic and oppressive action." She also filed a complaint for constructive dismissal, non-payment of premium pay, overtime pay, and damages.
Employer’s Defense
- The company claimed Recalde was transferred due to dishonesty, specifically using the company vehicle to scout for a new residence without permission. They cited loss of trust and confidence but chose not to dismiss her outright, citing compassion for the Christmas season.
Labor Arbiter’s Decision
- The Labor Arbiter ruled in favor of Recalde, finding the transfer unreasonable and humiliating. The company was ordered to reinstate her with full back wages and premium pay for May 22, 1994.
NLRC’s Affirmation
- The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision, and the company’s motion for reconsideration was denied.
Issue:
- Whether Recalde’s transfer from the laboratory to the vegetable processing section constituted constructive dismissal.
- Whether the company’s exercise of management prerogative in transferring Recalde was valid.
- Whether Recalde was entitled to premium pay for work performed on May 22, 1994.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court upheld the NLRC’s ruling, finding that Recalde was constructively dismissed and entitled to reinstatement, back wages, and premium pay. The company’s actions were deemed unreasonable and in violation of labor laws.