Title
Cambil vs. Kabalikat para sa Maunlad na Buhay, Inc.
Case
G.R. No. 245938
Decision Date
Apr 5, 2022
Probationary employee dismissed for failing to meet communicated performance standards; SC upheld termination, citing valid grounds and due process compliance.
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Case Digest (G.R. No. 245938)

Facts:

Employment and Training

Cattleya R. Cambil (petitioner) was hired by Kabalikat Para sa Maunlad na Buhay, Inc. (KMBI) as a Program Officer for Credit Group on May 30, 2016, on a probationary basis. She underwent a one-week Basic Operations Training Program from June 1 to 7, 2016, and was provided with an employment packet on June 2, 2016, which included her Appointment Letter, Performance Standards, KMBI Code of Ethics, Job Description, and Code of Conduct.

Termination of Employment

The parties conflicted on the date of termination: petitioner claimed she was terminated on July 22, 2016, while KMBI asserted it was on August 1, 2016. Petitioner alleged she was informed of her termination on July 22, 2016, after reporting for work despite feeling ill. KMBI, however, stated that petitioner’s termination was due to her failure to meet performance standards, as evidenced by her 67.50% overall rating in her Performance Evaluation Report.

Dispute and Proceedings

Petitioner filed a complaint for illegal dismissal with the Department of Labor and Employment (DOLE). The Labor Arbiter (LA) ruled in her favor, awarding her unpaid wages and wages for the unexpired portion of her probationary contract. The National Labor Relations Commission (NLRC) affirmed the LA’s decision. KMBI filed a Petition for Certiorari with the Court of Appeals (CA), which reversed the NLRC’s decision, ruling that petitioner’s dismissal was valid due to her failure to meet KMBI’s performance standards.

Issue:

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Ruling:

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Ratio:

  1. Probationary Employment Standards: Employers must communicate the reasonable standards for regularization to probationary employees at the time of engagement. KMBI substantially complied by providing petitioner with the performance standards during her training.
  2. Valid Termination: A probationary employee may be terminated for failing to meet the employer’s reasonable standards. KMBI’s dissatisfaction with petitioner’s performance and behavior was in good faith and supported by substantial evidence.
  3. Due Process: KMBI complied with due process requirements by issuing a written notice of termination and providing petitioner an opportunity to explain her actions.
  4. Social Justice vs. Employer’s Rights: While labor laws protect employees, employers also have the right to terminate probationary employees who fail to meet reasonable standards or exhibit misconduct.


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