Case Digest (G.R. No. L-63316)
Facts:
Iluminada Ver Buiser, Ma Cecilia Rillo-Acuna and Ma. Mercedes P. Intengan v. Hon. Vicente Leogardo, Jr., G.R. No. L-63316, July 31, 1984, Supreme Court Second Division, Guerrero, J., writing for the Court.Petitioners Iluminada Ver Buiser, Ma. Cecilia Rillo-Acuna and Ma. Mercedes P. Intengan were employed by private respondent General Telephone Directory Company as telephone sales representatives tasked with soliciting advertisements for the PLDT telephone directory. Buiser and Intengan executed an "Employment Contract (on Probationary Status)" on May 26, 1980, and Rillo-Acuna executed the same contract on June 11, 1980. The contracts expressly stated a probationary period of eighteen (18) months (May 1980–October 1981) and contained a clause permitting termination during probation "at the pleasure of the company" without notice or termination pay; the contracts also required that employees meet prescribed sales quotas.
Petitioners failed to meet their respective sales quotas and were dismissed: Buiser and Rillo-Acuna on May 14, 1981, and Intengan on May 18, 1981. On May 27, 1981, they filed with the National Capital Region, Ministry of Labor and Employment, a complaint for illegal dismissal and claims for back wages, commissions and other benefits, docketed as Case No. NCR-STF-5-2851-81.
The Regional Director, National Capital Region, in an Order dated September 21, 1982, dismissed the complaints except for an award of allowances. Petitioners filed a motion for reconsideration on September 30, 1982, which was treated as an appeal to the Minister of Labor. Deputy Minister Vicente Leogardo, Jr. issued an Order dated January 7, 1983, affirming the Regional Director’s decision, holding that the eighteen-month probationary period was valid and that petitioners’ dismissal for failure to meet sales quotas was justified.
Petitioners sought relief in the Supreme Court by a petition for certiorari (alleging grave abuse of discretion amounting to lack or excess of jurisdiction), contending primarily that (1) the probationary period exceeded the six-month maximum under Articles 2...(Pro-only)
Issues:
- Did the labor authorities commit grave abuse of discretion in upholding an eighteen-month probationary employment when Article 282 of the Labor Code generally limits probation to six months?
- Did the labor authorities commit grave abuse of discretion in finding that petitioners’ dismissal for failure to meet sales quotas constituted a just cause?
- Are petitioners entitled to commissions under the September 1981 Collective Bargaining Agreemen...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)