Case Digest (G.R. No. 108001) Core Legal Reasoning Model
Facts:
This case involves Mariwasa Manufacturing, Inc. and its Vice-President for Administration, Angel T. Dazo (petitioners), who employed Joaquin A. Dequila (private respondent) as a general utility worker on probation starting January 10, 1979. The initial probationary period was set at the six months prescribed by Article 282 of the Labor Code. Upon the expiration of that period in July 1979, Mariwasa informed Dequila that his performance was unsatisfactory and failed to meet company standards. Instead of terminating his employment, Mariwasa, with Dequila’s written consent, extended the probationary period for another three months from July 10 to October 9, 1979, to allow Dequila to improve his performance. Despite this extension, Dequila did not meet the required standards, leading to the termination of his employment. Dequila subsequently filed a complaint with the Ministry of Labor for illegal dismissal and violation of Presidential Decrees Nos. 928 and 1389 against Mariwasa an
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Case Digest (G.R. No. 108001) Expanded Legal Reasoning Model
Facts:
- Parties and Employment Background
- Private respondent Joaquin A. Dequila was hired on probation by petitioner Mariwasa Manufacturing, Inc. as a general utility worker starting January 10, 1979.
- The probationary period was set for six months, as prescribed by Article 282 of the Labor Code.
- Events During Probation
- Upon expiration of six months, Dequila’s performance was deemed unsatisfactory and failing to meet company standards.
- Mariwasa, with Dequila’s written consent, extended his probationary period for an additional three months (July 10 to October 9, 1979) to give him a chance to improve.
- Dequila’s performance did not improve during the extension, leading Mariwasa to terminate his employment at the end of the extended period.
- Administrative Proceedings
- Dequila filed a complaint for illegal dismissal and violation of Presidential Decrees Nos. 928 and 1389 against Mariwasa and its Vice-President of Administration, Angel T. Dazo.
- The Ministry of Labor’s Director Francisco L. Estrella dismissed the complaint for lack of merit after hearing.
- On appeal, Deputy Minister Vicente Leogardo reversed the dismissal, ruling that Dequila was already a regular employee when terminated and ordered his reinstatement with full back wages.
- The reinstatement order was later amended to limit back wages only until December 20, 1982.
- Petition for Review
- Mariwasa Manufacturing, Inc. and Angel T. Dazo petitioned the Supreme Court to review and set aside Deputy Minister Leogardo’s decision, arguing grave abuse of discretion and lack of jurisdiction.
- The central issue raised was whether Article 282 of the Labor Code, which limits probationary employment to six months, can be validly extended by agreement between employer and employee.
Issues:
- Whether the probationary period prescribed under Article 282 of the Labor Code can be validly extended beyond six months by agreement of the employer and employee.
- Whether the extension of probationary employment granted to Dequila, with his consent, made him a regular employee upon expiration of the original six-month period.
- Whether the termination of Dequila’s employment constituted illegal dismissal.
- Ancillary issue (not reached by the Court): Whether the back wages awarded were properly computed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)