Title
Sagun vs. ANZ Global Services and Operations , Inc.
Case
G.R. No. 220399
Decision Date
Aug 22, 2016
The job applicant's employment contract was suspended due to background check discrepancies, leading to the dismissal of his illegal termination claim.
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Case Digest (G.R. No. 220399)

Facts:

  • Enrique Y. Sagun (petitioner) filed a case against ANZ Global Services and Operations (Manila), Inc., Gay Cruzada, and Paula Alcaraz (respondents).
  • Sagun applied online for a position at ANZ after being employed at HSBC-EDPI.
  • He passed the interview and online examination, receiving a job offer on June 8, 2011, for the role of Customer Service Officer.
  • The employment agreement required satisfactory results from a pre-employment screening, including a police record check.
  • Sagun accepted the offer and resigned from HSBC-EDPI on June 11, 2011, planning to report to ANZ by July 11, 2011.
  • On July 11, 2011, Sagun was given a letter retracting the job offer due to inconsistencies in his application, particularly regarding his previous employment at Siemens.
  • Sagun argued that the employment contract was perfected upon acceptance and claimed he could only be dismissed for cause.
  • He filed a complaint for illegal dismissal with the National Labor Relations Commission (NLRC), which was dismissed by the Labor Arbiter for lack of merit.
  • The NLRC upheld the Labor Arbiter's decision, leading Sagun to appeal to the Court of Appeals (CA), which affirmed the NLRC's ruling.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the petition lacked merit, affirming the decisions of the Court of Appeals and the NLRC.
  • It concluded that no employer-employee relationship was established due to the conditio...(Unlock)

Ratio:

  • The Court explained that a contract is formed through a meeting of minds, requiring consent, a definite object, and a lawful cause.
  • Although the employment contract was perfected upon Sagun's acceptance, it was subject to suspensive conditions, specifically the satisfactory completion of background checks.
  • Citing Article 1181 of the Civil Code, the Court noted that the acqui...continue reading

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