G.R. No. L-75782 - Euro-Linea, Phils., Inc. vs. National Labor Relations Commission

The case involves Euro-Linea Phils., Inc. (petitioner) challenging the resolution of the National Labor Relations Commission (NLRC) which upheld the Labor Arbiter’s decision ordering the reinstatement of Jimmy O. Pastoral with six months backwages.
The petition is for review on certiorari under G.R. No. 75782 dated December 01, 1987, before the First Division of the Supreme Court.

On August 17, 1983, petitioner hired Pastoral as a shipping expediter on a probationary basis for six months, ending on February 18, 1984.
Prior to his engagement with petitioner, Pastoral had more than one and a half years of experience as a shipping expediter with Fitscher Manufacturing Corporation.
Despite his prior experience and subsequent absorption by the petitioner, Pastoral’s employment remained on a probationary basis.
Pastoral received a memorandum dated January 31, 1984, terminating his probationary employment effective February 4, 1984, on grounds of his failure “to meet the performance standards set by the company.”

To challenge his dismissal, Pastoral filed a complaint for illegal dismissal on February 6, 1984.
On July 19, 1985, the Labor Arbiter found petitioner guilty of illegal dismissal and ordered his reinstatement with six months backwages.
The petitioner appealed the decision to the NLRC on August 5, 1985, but the appeal was dismissed on July 16, 1986, as reflected in the NLRC resolution.
Subsequently, the petitioner raised errors before the Supreme Court, arguing that:

The Labor Arbiter decided a legal question in contravention of the spirit and purpose of the law; and
There was a grave abuse of discretion on the part of the Labor Arbiter for ignoring material facts in favor of the employee.

In various resolutions, the Court allowed both parties to comment and file memoranda.
The matter was given due course whereby the sole issue became whether the NLRC acted with grave abuse of discretion amounting to an excess of jurisdiction in ruling against the dismissal of a probationary employee.
Central point: Although probationary employees have limited tenure, they are still constitutionally protected with regard to security of tenure and may only be dismissed for just cause.

Whether the dismissal of Pastoral, a temporary or probationary employee, was justified given his failure to meet purported performance standards.
Whether the NLRC committed grave abuse of discretion or exceeded its jurisdiction in affirming the Labor Arbiter’s decision ordering reinstatement and backwages.
Whether the employer’s decision, based solely on an alleged failure to meet performance standards without presenting specific instances or evidence, constitutes just cause for termination.