Case Summary (G.R. No. 164893)
Facts of the Case
Duldulao was hired in June 1987, but in August 1996, a law student complained about her performance. Despite receiving extensions, she failed to submit her answer to the complaint. Consequently, on October 1, 1996, Dean Honorato V. Aquino recommended her reassignment due to her failure to respond and her admission of inappropriate interactions with students. The Vice President for Administration issued a Department Order reassigning her to the High School and Elementary Departments effective October 2, 1996. Duldulao subsequently filed a motion for reconsideration and requested an extension, but her concerns were escalated to the Executive Board.
Administrative Proceedings and Findings
Duldulao filed a complaint with BCF's Grievance Committee regarding her reassignment, but due to her non-union status, it was forwarded to the Administrative Investigating Committee. On January 21, 1997, the Committee upheld the reassignment, which was aimed at preserving harmony within the College of Law, and recommended that she start her new assignment. This recommendation was approved by BCF's President. Even though a Fact-Finding Committee found no guilt against Duldulao, she did not report to her new assignment and took a leave of absence instead.
Filing of Constructive Dismissal Complaint
On February 17, 1997, Duldulao filed a complaint for constructive dismissal with the NLRC, asserting that the reassignment was punitive and financially burdensome. Initially, the Executive Labor Arbiter ruled in her favor, ordering reinstatement and awarding damages. However, on appeal, the NLRC reversed this ruling, finding her transfer legitimate and not constitutive of constructive dismissal.
Court of Appeals Ruling
The Court of Appeals upheld the NLRC's ruling, asserting that the reassignment was not motivated by malice nor conducted as a disciplinary measure. The court found no evidence that the transfer amounted to bad faith or ill will against Duldulao.
Arguments Presented
In her petition, Duldulao maintained that her reassignment constituted constructive dismissal, arguing that it was done in bad faith and amounted to punitive action. Conversely, respondents argued that the transfer was a legitimate management prerogative intended to address the situation arising from the complaint against her, and it was neither a demotion nor a dismissal since her salary and benefits remained intact.
Legal Principles and Context
The issue of constructive dismissal hinged on whether the reassignment constituted an act of discrimination or insensitivity that would compel an employee to relinquish their position. It is established that an employee does not have an inherent right to remain in a specific position; management retains the prerogative to transfer employees within its organization as long as the action is justifiable, non-discriminatory, and does not involve demotion or substantial inconvenience.
Findings on Constructive Dismissal and Management Prerogative
The Supreme Court reaffirmed that the findings of quasijudicial bodies, like the NLRC, deserve respect unless grave abuse o
...continue readingCase Syllabus (G.R. No. 164893)
Case Citation
- 546 Phil. 22; 104 OG No. 5, 705 (February 4, 2008)
- G.R. No. 164893, March 01, 2007
Parties Involved
- Petitioner: Constancia P. Duldulao
- Respondents: The Court of Appeals and Baguio Colleges Foundation (BCF)
Procedural History
- The case is a petition for review under Rule 45, aimed at setting aside the decision of the Court of Appeals in CA-G.R. SP No. 58291.
- The Court of Appeals affirmed the National Labor Relations Commission (NLRC) decision dated September 30, 1999, in NLRC CASE RAB-CAR-02-0076-97, NLRC NCR CA NO. 018861-99.
Facts of the Case
Employment Background:
- Petitioner Constancia P. Duldulao was employed by Baguio Colleges Foundation as a secretary/clerk-typist for the College of Law since June 1987.
Incident Leading to Reassignment:
- In August 1996, a law student lodged a complaint against the petitioner for alleged work irregularities.
- Petitioner was asked to submit an answer to the complaint but failed to do so despite receiving several extensions.
Department Order for Transfer:
- On October 1, 1996, Dean Honorato V. Aquino recommended to BCF President Atty. Edilberto B. Tenefrancia that Duldulao be reassigned due to her failure to respond to the complaint and her admitted fraternization with students.
- A Department Order was issued on the same day, transferring her to the office of the Principals of the High School and Elementary Departments effective October 2, 1996.
Petitioner's Response:
- Duldulao filed a motion for reconsideration and requested an extension to file her answer, which Dean Aquino stated could not be acted upon as the matter was elevated to the Executive Board.
- She eventually submitted her answer on October 7, 1996.
Grievance and Investigation:
- Duldulao filed a grievance with the BCF Grievance Committee regarding her reassignment, claiming it was arbitrary and capricious.
- The case was transferred to the Administrative Investigat