Case Summary (G.R. No. 116123)
Antecedent Facts
Del Villar was hired on May 1, 1990, earning a salary of ₱50,000 per month and enjoying various benefits, including a company car. In 1992, he was reassigned as Transportation Services Manager, overseeing vehicle budgeting nationwide. His situation changed drastically after submitting a report in January 1996, accusing Company officials, including Edgardo I. San Juan and Jose L. Pineda, of fraudulently inflating truck prices. Seven months after this report, Del Villar was reassigned to the position of Staff Assistant to the Corporate Purchasing and Materials Control Manager, resulting in the withdrawal of most of his benefits.
Filing of Complaint
Feeling demoted and harassed, Del Villar filed a complaint against the Company for illegal demotion and forfeiture of privileges on November 11, 1996. He included the Company President and several executives as respondents. The Company failed to appear for the initial hearing and opted to file a Motion to Dismiss, claiming Del Villar had no cause of action. The NLRC Labor Arbiter eventually ruled in favor of Del Villar, asserting that his demotion lacked justification and was retaliatory in nature due to his earlier whistleblowing.
NLRC Decision
The NLRC, in a decision dated February 26, 1999, reversed the Labor Arbiter's ruling, asserting that Del Villar's transfer did not equate to demotion and that the Company acted in good faith. They required evidence of bad faith which they found lacking due to the Company's investigation into the alleged fraudulent activities and the absence of a clear link between the transfer and Del Villar's report.
Court of Appeals Ruling
Del Villar appealed to the Court of Appeals, which ruled in his favor on October 30, 2003. The appellate court determined that the NLRC erred in its evaluation, as the change in Del Villar’s job title and the withdrawal of his benefits clearly indicated a demotion. The Court found evidence of the Company’s bad faith, asserting that the purported reorganization lacked necessary disclosure and motivation.
Reconsideration and Final Appeals
Both parties subsequently filed motions for partial reconsideration, which the Court of Appeals denied on March 29, 2004. The Company raised multiple grounds in their petition for review, claiming errors in the appellate court's decision and advocating that Del Villar's position was no longer necessary due to redundancy.
Supreme Court Ruling
In reviewing the case, the Supreme Court upheld the Court of Appeals' decision, concluding that Del Villar's transfer constituted constructive dismissal. The Court emphasized that the burden of proving
...continue readingCase Syllabus (G.R. No. 116123)
Case Background
- Petitioner Coca-Cola Bottlers Philippines, Inc. (the Company) filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petition sought to reverse:
- The Decision dated October 30, 2003, of the Court of Appeals (CA-G.R. SP No. 53815) which overturned the decision of the National Labor Relations Commission (NLRC) dated February 26, 1999.
- The Resolution dated March 29, 2004, denying the Company's Motion for Reconsideration.
- Respondent Angel U. Del Villar was initially hired on May 1, 1990, as Physical Distribution Fleet Manager, later promoted to Transportation Services Manager during a reorganization in 1992.
Allegations of Fraud and Subsequent Demotion
- Del Villar reported a fraudulent scheme involving overpricing of trucks, implicating high-ranking officials including Edgardo I. San Juan and Jose L. Pineda, Jr.
- Following his report, a reorganization led to Del Villar's demotion to Staff Assistant to the Corporate Purchasing and Materials Control Manager, removing his car and other benefits while retaining his salary.
- Del Villar viewed this demotion as a forced resignation due to harassment.
Procedural History
- Del Villar filed a complaint for illegal demotion on November 11, 1996, aga