Case Digest (G.R. No. 228357) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves a complaint for illegal dismissal filed by Geraldine M. Barbosa against petitioner C.P. Reyes Hospital and Angeline M. Reyes. Barbosa was hired by C.P. Reyes Hospital as a Training Supervisor on probation starting September 4, 2013, under a six-month probationary contract. Her contract required her to maintain an average passing score of 80% during her training and evaluation. She was to train in various capacities before final regularization. Barbosa received satisfactory marks in her evaluations but was terminated by the hospital on November 29, 2013, before the end of her probationary period, on grounds including unsatisfactory performance and absenteeism. Barbosa contested her dismissal as illegal, citing that she complied with the standards, satisfactorily explained absences, and was not given proper due process. The Labor Arbiter ruled in favor of Barbosa, finding her dismissal illegal and awarding her backwages and separation pay. The National Labor Rel Case Digest (G.R. No. 228357) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment of Geraldine M. Barbosa at C.P. Reyes Hospital
- Barbosa was hired by C.P. Reyes Hospital as a Training Supervisor on a probationary basis for six months, from September 4, 2013, to March 4, 2014.
- Her contract required her to maintain an average passing score of at least 80% during her training, failing which could warrant termination.
- Barbosa was evaluated monthly and received passing marks: an average of 81.68% in the first month and 82.59% in the second month.
- Despite passing grades, evaluators noted deficiencies in initiative, time management, documentation, and interpersonal relations.
- Termination of Employment
- On November 27, 2013, Barbosa received a Notice to Explain for absenteeism on November 4, 7, and 8, 2013.
- Barbosa explained her absences, providing medical certificates and leave forms.
- On November 29, 2013, she was formally terminated effective December 30, 2013, based on negative performance feedback and attendance issues.
- Proceedings before Labor Arbiter, NLRC, and CA
- The Labor Arbiter (LA) ruled Barbosa was illegally dismissed, awarding PHP 60,000 backwages and PHP 10,000 separation pay.
- The National Labor Relations Commission (NLRC) reversed the LA, finding valid termination based on performance comments and attendance records.
- Barbosa petitioned to the Court of Appeals (CA), which reversed the NLRC decision, ruling her dismissal illegal due to noncompliance with her probationary contract requirements and lack of substantial absences.
Issues:
- Whether Barbosa's dismissal was legal considering her probationary status and performance evaluations.
- Whether C.P. Reyes Hospital complied with due process in terminating Barbosa.
- Whether backwages should be computed from the date of dismissal to the finality of decision or only until the end of the probationary period.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)