Facts:

• Romeo T. Sto. Tomas was dismissed from his role as a Senior Accounting Analyst at Caltex (Philippines), Inc. on July 31, 1997, due to redundancy.
• He had been employed since February 2, 1984, earning a monthly salary of P29,860.
• On October 21, 1996, Caltex notified the Department of Labor and Employment (DOLE) about its intention to implement a redundancy program to streamline operations.
• Sto. Tomas received a termination notice on June 30, 1997, along with a separation package totaling P559,458.90, which included regular benefits and an ex-gratia payment.
• After his dismissal, Sto. Tomas filed a complaint for illegal dismissal, claiming entitlement to security of tenure and asserting that his termination lacked due process.
• The Labor Arbiter initially dismissed his complaint, but the National Labor Relations Commission (NLRC) later reversed this decision, declaring the dismissal illegal and ordering reinstatement and backwages.
• The Court of Appeals upheld the NLRC's ruling, prompting Caltex to file a petition for review with the Supreme Court.

Issue:

• (Unlock)

Ruling:

• The Supreme Court affirmed the decisions of the Court of Appeals and the NLRC, ruling that Sto. Tomas's dismissal was illegal due to insufficient evidence of redundancy and failure to comply with the notice requirement to the DOLE....(Unlock)

Ratio:

• The Supreme Court highlighted the necessity for employers to present substantial evidence to justify a dismissal based on redundancy, proving that the employee's position was genuinely unnecessary.
• Caltex did not provide adequate proof of redundancy beyond a notification letter to the DOLE regarding the intention to implement a redundancy program.
• Redundancy must be substantiated by concrete factors, such as overhiring or a decline in business volume, which Caltex failed to demonstrate.
• The lack of a written notice to the DOLE one month prior to Sto. Tomas's termination constituted a signific...continue reading