G.R. No. 191154 - SPI Technologies, Inc. vs. Mapua

Victoria K. Mapua was hired in 2003 by SPI Technologies, Inc. as the Corporate Development/Research – Business Intelligence Unit Head and Manager.
In August 2006, Peter Maquera, then Vice President and Corporate Development Head, appointed Elizabeth Nolan as Mapua’s supervisor.

In October 2006, Mapua’s laptop hard disk crashed, causing loss of files and data. She immediately sought assistance from the National Bureau of Investigation Anti-Fraud and Computer Crimes Division to recover the data.
After resolving the data issue, Mapua was informed by Nolan that her position was being realigned, including becoming subordinate to co-manager Sameer Raina, due to alleged underperformance––specifically citing missed deadlines, frequent absences, undertime when Maquera was unavailable, and perceived leniency compared to other hard-working colleagues.
On November 16, 2006, Mapua produced a summary of her attendance over the past six months to refute claims regarding frequent absences and undertime; however, Nolan dismissed the matter without rectification.

In December 2006, Mapua observed a marked change in the workplace environment – her colleagues began to ostracize her, and her duties were reassigned largely to rank-and-file staff.
Mapua lost approximately 95% of her work projects and responsibilities.
Seeking relief, Mapua consulted with Lea Villanueva, the Human Resource Director of SPI, and requested a transfer to another department. Villanueva mentioned an available intra-office opening and promised to schedule an exploratory interview, though multiple postponements ensued.

On February 28, 2007, Mapua saw the new table of organization for the Corporate Development Division, which was being renamed as the Marketing Division. The new structure clearly illustrated that her rank would be downgraded, with a new managerial position inserted between her and Sameer Raina.
On March 21, 2007, Raina informed Mapua via telephone that her position was deemed redundant and that she was terminated effective immediately. Villanueva subsequently notified her to stop reporting for work the following day.
In subsequent events, Mapua was issued not one but multiple termination letters:

The first termination letter indicated an immediate effectivity (March 21, 2007).
A mailed letter later stated the effective termination date as April 21, 2007.
A third notice, received on April 25, 2007, also reiterated the April 21, 2007 effective date, included details about separation pay, and contained a clause for “refusal to sign and acknowledge” in unintelligible witness signatures.

Concurrently, Mapua’s company-issued laptop, mobile phone, and ID were immediately confiscated.

Mapua, shocked by her sudden termination, threatened legal action and, on March 27, 2007, filed a complaint for illegal dismissal before the Labor Arbiter, seeking reinstatement or separation pay.
SPI countered Mapua’s allegations by stating that its regular evaluation of corporate operations prompted a reorganization, as evidenced by an August 28, 2006 Inter-Office Memorandum.
SPI presented affidavits by HR Director Villanueva claiming that Mapua’s functions were being adequately performed by other personnel in the company.
Furthermore, a recruitment advertisement published on May 13, 2007 in the Philippine Daily Inquirer, and a later alleged Jobstreet advertisement via Prime Manpower, were introduced to challenge Mapua’s claim that her position was not redundant.

The Labor Arbiter (LA) issued a decision on June 30, 2008, declaring Mapua’s termination illegal, and awarded backwages, separation pay, moral and exemplary damages, attorney’s fees, and even the company car assigned to her.
On October 24, 2008, the National Labor Relations Commission (NLRC) reversed the LA decision by finding the appellants not guilty of illegal dismissal yet ordered payment of separation benefits and final pay.
The Court of Appeals (CA) reinstated the LA decision on October 28, 2009 (with modifications reducing the 13th month pay), leading to SPI filing a petition for review on certiorari before the Supreme Court.

Whether Mapua’s position as Corporate Development Manager was genuinely redundant.
Whether the reorganization and realignment of duties within SPI sufficed to prove redundancy.

The effectiveness of the written notice requirement in light of the conflicting termination letters (one effective immediately and one effective on April 21, 2007).
Whether Mapua was afforded her right to a 30-day notice as mandated under Article 283 of the Labor Code.

Compliance with Statutory and Jurisprudential Requirements for a Redundancy Program

Whether SPI complied with the requirement to serve a written notice to both the employee and the Department of Labor and Employment one month prior to termination.
Whether the separation pay offered and the criteria employed were fair, reasonable, and in good faith.

Whether a change in job title (i.e., from Corporate Development Manager to a potential Marketing Communications Manager) can be equated with a change in the actual functions performed by the employee.

Whether corporate officers (Villanueva, Nolan, Maquera, and Raina) should be held individually and solidarily liable for the alleged unlawful dismissal.