Case Digest (G.R. No. 258269)
Facts:
Jose Antonio Paolo I. Reyes v. Samsung Electronic Phils. Corp., G.R. No. 258269, April 15, 2024, Supreme Court Second Division, Lopez, J., writing for the Court.Petitioner Jose Antonio Paolo I. Reyes (Reyes) was hired by respondent Samsung Electronic Phils. Corp. (Samsung) as WLAN Head/National Sales Manager on probation starting March 27, 2017; Samsung President and/or Managing Director Kevin Lee personally invited him and Samsung offered a monthly compensation of PHP 470,000. Reyes executed a Probationary Contract of Employment and a Side Agreement on benefits. The offer letter and contract expressly described his status as probationary and provided that performance standards would be made known and that evaluation would occur on the fifth month.
On August 23, 2017 Samsung, through IMT Acting Head Rhinn Piczon, notified Reyes that he failed to meet standards and that his probationary employment would be terminated effective September 27, 2017. The termination letter attached Reyes’ Performance Evaluation Form, showing an overall assessment of 4.08 (on a scale where 5 is the lowest) and a “Needs Improvement” rating. Reyes filed a complaint with the Labor Arbiter (LA) for illegal dismissal, nonpayment of 13th month pay, regularization, moral and exemplary damages, and attorney’s fees, impleading Lee, Senior Business Director Minsu Chu, and Director for Human Relations Silver Fungo as officers of Samsung.
The LA (Labor Arbiter Augusto L. Villanueva) dismissed Reyes’ complaint for lack of merit, holding that Reyes had acknowledged in the contract that performance standards were explained at commencement, that “do what you think is right” referred to discretion in performance rather than absence of standards, and that adequate performance of duties is an implied standard for regularization; the LA nevertheless ordered payment of Reyes’ proportionate 13th month pay of PHP 235,000. Reyes appealed to the National Labor Relations Commission (NLRC).
The NLRC (Sixth Division) affirmed the LA’s decision in full, finding that Reyes failed to specifically deny Chu’s and Piczon’s affidavits that standards and expectations were relayed at the start and reiterated during meetings, that qualitative and quantitative expectations existed, and that performance feedback was given; it admitted those affidavits as competent evidence. Reyes’ motion for reconsideration before the NLRC was denied.
Reyes then filed a petition for certiorari with the Court of Appeals (CA) challenging the NLRC decision. The CA (Fifth Division) denied the...(Pro-only)
Issues:
- Did the Court of Appeals correctly determine that the NLRC did not commit grave abuse of discretion in finding that Reyes was not a regular employee?
- Were the employer’s reasonable standards for regularization made known to Reyes at the time of his engagement?
- Was Reyes’ termination illegal and is the two-notice rule applicable to his dismissal for failure to...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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