G.R. No. 181735 - Land Registration Authority vs. Lanting Security and Watchman Agency

Petitioners: Tamsonas Enterprises, Inc., Nelson Lee (company President), Lilibeth Ong, and Johnson Ng.
Respondent: Rosemarie L. Sy, former employee.
Case arose from a complaint of illegal dismissal and monetary claims filed by Sy against petitioners before the National Labor Relations Commission (NLRC).

Sy was hired as Assistant to the President on September 1, 2006, but was assigned duties as payroll officer/clerk.
She was considered a probationary employee with a six-month probationary period ending February 28, 2007.
On February 24, 2007, Sy was told by Ng and Lee that her services would be terminated due to inefficiency.
She was asked to sign a resignation and quitclaim letter but refused.
Sy was prevented from collecting her personal belongings and was humiliated by co-employee Ong on her last day.

Sy denied allegations of inefficiency, citing perfect attendance, overtime work, and good performance.
Petitioners claimed Sy was informed she was a probationary employee subject to standards set by the company and that she failed to meet these.
Sy allegedly threatened petitioners’ families, contributing to non-regularization decision.

Labor Arbiter (ELA) ruled Sy’s dismissal illegal due to lack of just cause and due process.
NLRC reversed the decision, holding the dismissal valid under Article 281 of the Labor Code for failure to qualify as a regular employee.
Court of Appeals (CA) reinstated the Labor Arbiter’s decision, finding no standards were made known to Sy and no due process was observed.

Whether or not Sy’s termination as a probationary employee was valid.
Whether the petitioners complied with the requirement of informing Sy of reasonable standards for regularization at the time of engagement.
Whether due process and just cause were observed in the dismissal.