G.R. No. 226244 - Yonzon vs. Coca-Cola Bottlers Philippines, Inc.

Anniebel B. Yonzon was hired by Coca-Cola Bottlers Philippines, Inc. as an HR Generalist on December 1, 2010.
She was terminated on April 30, 2011 for allegedly failing to meet undisclosed quality standards of the company.
Yonzon filed a complaint for illegal dismissal, regularization, damages, and attorney’s fees against Coca-Cola and certain company officers (Carranza and Villa) in her first labor case (docketed as NLRC-NCR-05-08155-11).

The Labor Arbiter dismissed Yonzon’s complaint for lack of merit, noting that although she did not divulge a trade secret, her unauthorized use of confidential co-employees’ salary data was a breach of company rules and the rights of her co-employees.
On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision. It declared her dismissal illegal and ordered her reinstatement as a regular employee along with full backwages from her dismissal date until finality, also awarding attorney’s fees (10% of the judgment award).

Yonzon filed a Motion for Partial Reconsideration (July 5, 2012) seeking moral and exemplary damages and additional attorney’s fees alleging bad faith in her termination, linking her health condition (myomas) as a precipitating factor.
After being reinstated, but in a different position (HR Staff rather than HR Generalist), she filed a Motion for Execution (October 22, 2012) demanding reinstatement to her original position with corresponding salary adjustment and a recomputation of backwages.
With no action on her motions for reconsideration and execution, she filed a Third Motion (March 14, 2014) asking the NLRC to review the correctness of her reinstatement and wage recomputation, grant additional damages and costs, and even declare company officials in contempt for subverting the NLRC decision.

In her legal pleadings before the NLRC, Yonzon disclosed the salaries of her co-employees to show that she was underpaid compared to them, alleging discriminatory treatment.
On March 21, 2014, Coca-Cola issued a Notice to Explain (NTE) and imposed a 30-day preventive suspension without pay, alleging that Yonzon had disclosed confidential employee salary information in violation of internal policies and the company’s Red Book and Code of Business Ethics.
Although Yonzon explained that her disclosure was directed to an officer of the court as part of her case, on April 23, 2014, Coca-Cola dismissed her through a Notice of Decision on the grounds of unauthorized disclosure leading to loss of trust and confidence.

The Labor Arbiter, in a Decision dated December 29, 2014, dismissed the complaint for lack of merit and denied the claim for underpayment, emphasizing that the unauthorized disclosure breached confidentiality rights.
The NLRC reversed the Labor Arbiter’s decision on May 20, 2015, ruling that Yonzon was illegally dismissed/suspended and ordering her reinstatement with full backwages, additional benefits, and attorney’s fees, while denying other claims.
Coca-Cola filed for reconsideration, which was denied, and the case was elevated to the Court of Appeals (CA) via a petition for certiorari.

On May 23, 2016, the CA annulled the NLRC ruling and reinstated the Labor Arbiter’s Decision, ruling that Yonzon’s dismissal was valid based on the loss of trust and confidence resulting from her unauthorized disclosure.
The CA emphasized that as an HR Administration Analyst, Yonzon had access to sensitive company information and should have sought proper authorization before disclosing it.
Yonzon subsequently filed a motion for reconsideration before the CA, which was denied on August 2, 2016, prompting her to petition for review before the Supreme Court.

Yonzon argued that the disclosure of salary information did not constitute a breach of trade secrets or confidential information, as her intent was to support her claim of discriminatory pay practices.
She further asserted that Rule 3, Section 31 of the Coca-Cola Red Book was vague and overbroad, thus failing to provide clear standards to determine what constituted classified or confidential information.
Coca-Cola countered that as an employee handling sensitive payroll data, Yonzon was in a position that mandated utmost confidence, and her unauthorized act justified her dismissal.

Whether the dismissal of Yonzon by Coca-Cola was validly effectuated based on the ground of loss of trust and confidence.

Whether Yonzon, who disclosed confidential salary information for the purpose of alleging discrimination, fell within the category of employees occupying a position of trust and confidence.
Whether the company’s enforcement of Rule 3, Section 31 of its Red Book—regarding the disclosure of classified/restricted/confidential information—was fair, reasonable, and sufficiently specific to justify dismissal.