G.R. No. 117040 - Serrano vs. National Labor Relations Commission

Ruben Serrano was hired by Isetann Department Store on October 4, 1984 as a contractual security checker, became a regular employee on April 4, 1985, and was appointed Head of the Security Checkers Section in 1988.
On October 11, 1991, Isetann phased out its internal security section to engage an independent security agency and served Serrano a memorandum terminating his employment effective that same day.

Serrano filed a complaint on December 3, 1991 alleging illegal dismissal, illegal layoff, unfair labor practice, underpayment of wages, and non-payment of salary and overtime.
On April 30, 1993, the Labor Arbiter held the dismissal illegal for lack of due process and bad faith in selection, ordering reinstatement, three years’ backwages (up to promulgation), unpaid wages (P 2,020.73), pro-rated 13th-month pay (P 3,198.30), and 10% attorney’s fees.
On March 30, 1994, the NLRC reversed, ruling that the abolition of the security section was a bona fide redundancy exercise under Article 283, and granted Serrano separation pay (one month per year of service), unpaid salary, and proportionate 13th-month pay; a motion for reconsideration was denied on August 26, 1994.
Serrano then petitioned the Supreme Court, contending that the phase-out did not fall under Art. 283 and that he was denied the mandatory 30-day notice.

Whether Isetann’s abolition of its Security Checkers Section and engagement of an outside agency constituted “redundancy” or another authorized cause under Article 283 of the Labor Code.
Whether Serrano was deprived of due process by Isetann’s failure to serve the 30-day written notice on him and on the Department of Labor and Employment.
What remedy or sanction is appropriate when an employee is dismissed for an authorized cause but without compliance with the Article 283 notice requirement.