Case Digest (G.R. No. 235794)
Case Digest (G.R. No. 235794)
Facts:
Karen G. Jaso v. Metrobank & Trust Co., G.R. No. 235794, May 12, 2021, Supreme Court Third Division, Inting, J., writing for the Court.Petitioner Karen G. Jaso was hired by respondent Metrobank & Trust Co. on July 16, 2012 as a Management Trainee. On January 2, 2013, Metrobank's Head of Employee Relations, Maria Zarah C. Hernandez, served a Show Cause Order charging petitioner with gross and habitual negligence, unprofessional behavior, and unauthorized absences; petitioner submitted a written explanation on January 9, 2013, but Metrobank dismissed her effective January 15, 2013. Petitioner alleged she had become a regular employee after six months, that the dismissal lacked due process and proof, and sought reinstatement, backwages, damages and attorneys’ fees; Metrobank maintained petitioner was a probationary employee who failed to meet performance standards and committed infractions.
At the Labor Arbiter (LA), petitioner prevailed: in a Decision dated May 2, 2013 the LA found illegal dismissal, ordered reinstatement and backwages, and exonerated the individual officers named as respondents. Metrobank appealed to the National Labor Relations Commission (NLRC). In a Decision dated January 30, 2014 the NLRC vacated the LA, holding petitioner was still a probationary employee when dismissed, that Metrobank had made known the standards for regularization, and that due process was observed; the NLRC denied reconsideration in a May 28, 2014 Resolution.
Petitioner filed a petition for certiorari with the Court of Appeals (CA). In a Decision dated September 13, 2017 and Resolution dated November 23, 2017 the CA dismissed the petition for lack of merit and affirmed the NLRC. Petitioner then filed this Petition for Review on Certiorari with the Supreme Court under Rule 45, assailing the CA rulings and reiterating that Metrobank failed to show the standards for regularization and that she had already become regular when dismissed.
Issues:
- Was Metrobank shown to have made known the reasonable standards for regularization to petitioner at the time of her engagement?
- Did petitioner fail to qualify as a regular employee under those standards such that her termination was valid?
- Was petitioner still a probationary employee on the date of her dismissal?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)