G.R. No. 238453 - People vs. Yanson

General Milling Corporation (GMC) is a domestic corporation with its principal office in Makati City and a manufacturing plant in Lapu-Lapu City.
Violeta L. Viajar, the respondent, was employed by GMC since August 6, 1979 and held several positions over the years, ultimately becoming a Purchasing Staff.

In October 2003, GMC terminated the services of thirteen employees, including Viajar, on the ground of redundancy as part of a downsizing measure for its Visayas-Mindanao (Vismin) Operations.
GMC asserted that a gradual reduction in manpower was necessary due to economic setbacks, falling profitability, and rising operating and interest expenditures.
The company issued a Letter-Memorandum (dated October 27, 2003) informing Viajar that her position was redundant and that her dismissal would be effective on November 30, 2003.

On October 31, 2003, when Viajar reported for work, she was barred from entering the premises, denied access to her office computer, and prevented from recording her attendance.
On November 7, 2003, Viajar was summoned to the HRD office and asked to sign an “Application for Retirement and Benefits,” which she refused since she had never applied for retirement but was terminated for redundancy.
Viajar noted that despite her termination, GMC continued hiring new employees, raising her suspicions over the legitimacy of the redundancy claim.
At the time of termination, her monthly salary was P19,651.41, and GMC subsequently issued two checks (amounting to P440,253.02 and P21,211.35) as separation pay.

On December 2, 2003, Viajar filed a Complaint for Illegal Dismissal before the NLRC’s Regional Arbitration Branch (RAB) No. VII, Cebu City.
The Labor Arbiter (LA) of RAB No. VII, Cebu City rendered a decision on April 18, 2005, holding that Viajar’s dismissal was justified on the ground of redundancy and that her claims for illegal dismissal and monetary benefits were without merit.
The NLRC, affirming the LA’s findings on October 28, 2005, ordered GMC to pay Viajar separation pay of P461,464.37 while noting that she did not need to contest the redundancy declaration with the DOLE.
Viajar filed a Motion for Reconsideration before the NLRC, which was denied in its Resolution dated January 31, 2006.

Dissatisfied with the NLRC’s decision, Viajar advanced a petition for certiorari before the Court of Appeals (CA).
In its Decision dated September 21, 2007, and subsequent Resolution dated January 30, 2008, the CA set aside the NLRC’s decision and ordered that Viajar be reinstated without loss of seniority and with full backwages from November 30, 2003.
The CA also awarded moral and exemplary damages of P50,000.00 each and attorney’s fees equivalent to 10% of the total monetary award, while imposing costs against GMC.
GMC filed a motion for reconsideration with the CA, which was denied, leading to the present petition for review on certiorari filed by GMC.

Whether the dismissal of Viajar on the ground of redundancy was validly executed and compliant with the procedural and substantive requirements under Article 283 of the Labor Code.
Whether the factual findings of the NLRC, which determined that Viajar’s termination was due to redundancy, should be accorded respect and finality or subject to re-evaluation by the CA.
Whether GMC has discharged its burden of proving by substantial evidence that the termination was justified by a genuine reduction in its manpower needs, including the necessity of a proper evaluation of redundancy.
Whether the CA committed grave abuse of discretion by setting aside the decisions of the NLRC and re-examining findings of fact already supported by evidence on record.
Whether the acts perpetrated by GMC—such as barring Viajar from entering company premises and compelling her to sign an “Application for Retirement and Benefits”—constitute bad faith that vitiates the ground of redundancy.