Case Summary (G.R. No. 246793)
Background
HCL, engaged in business process outsourcing, hired Guarin, Jr. on November 11, 2013, as a senior technical support officer assigned to assist Salesforce.com Inc. On July 5, 2016, Salesforce notified HCL that it would cease its services with HCL effective October 15, 2016. Consequently, HCL offered Guarin, Jr. three options: apply for a position with another client, seek a new role within HCL, or resign. After Guarin, Jr. missed the application deadline for available positions, HCL informed him on October 15, 2016, that his role was redundant and set his termination date for November 15, 2016. Guarin, Jr. received a separation package of PHP 182,340.65 and subsequently signed a release and quitclaim.
Ruling of the Labor Arbiter
The Labor Arbiter ruled on June 30, 2017, that Guarin, Jr. was illegally dismissed, ordering HCL to pay him full back wages, moral damages of PHP 100,000, and attorney’s fees of 10% of the total award. The Arbiter found that while HCL complied with the procedural requirements of redundancy, it failed the criteria of good faith in termination and did not follow fair and reasonable criteria in determining redundant positions.
Ruling of the National Labor Relations Commission
The NLRC partially granted appeals from both parties on October 30, 2017, affirming the Labor Arbiter’s finding of illegal dismissal. It stated that although HCL complied with procedural due process, it could not prove that the redundancy of Guarin, Jr.'s position was justified due to the existence of available positions within the company. The NLRC reduced the original damages awarded by dismissing moral and exemplary damages on the basis of a lack of bad faith from HCL, but upheld Guarin, Jr.'s entitlement to back wages.
Ruling of the Court of Appeals
The Court of Appeals upheld the NLRC’s ruling on January 29, 2019, confirming that HCL could not demonstrate good faith or fair criteria for its redundancy claim. The CA also invalidated the quitclaim signed by Guarin, Jr., asserting that fraud or deceit had been employed in its acquisition. However, the CA did award interest on the monetary claims from the date of finality of the decision.
Supreme Court Ruling
The Supreme Court, on March 18, 2021, granted HCL's petition, stating that the lower courts' findings of illegal dismissal were erron
...continue readingCase Syllabus (G.R. No. 246793)
Background of the Case
- The case involves HCL Technologies Philippines, Inc. (HCL) filing a Petition for Review on Certiorari against Francisco Agraviador Guarin, Jr. regarding a labor dispute.
- The initial Decision was made by the Court of Appeals (CA) on January 29, 2019, which affirmed the National Labor Relations Commission (NLRC) decision that found Guarin, Jr. was illegally dismissed.
- The NLRC had partially affirmed a prior ruling from the Labor Arbiter (LA) that ordered HCL to pay Guarin, Jr. full back wages, moral damages, and attorney's fees.
Employment and Dismissal Details
- Guarin, Jr. was hired by HCL on November 11, 2013, as a senior technical support officer for the client Salesforce.com Inc.
- On July 5, 2016, Salesforce notified HCL that it would terminate its services effective October 15, 2016, leading to the redundancy of Guarin, Jr.'s position.
- HCL offered Guarin, Jr. three options: apply for positions with Accenture, seek suitable roles within HCL (specifically for Google), or resign.
- Guarin, Jr. submitted his application after the deadline and was subsequently informed not to report to work starting October 1, 2016.
- A notice dated October 15, 2016, stated his position became redundant, with a final working day of November 15, 2016. He received a separation package of P182,340.65, which he acknowledged by signing a release, waiver, and quitclaim.
Labor Arbiter's Ruling
- On June 30, 2017, the LA ruled in favor of Guarin, Jr., declaring his dismissal illegal and ordering HCL to pay back wa