Case Summary (G.R. No. 234812)
Undisputed Facts
Respondent was initially hired on January 29, 1996, as a Financial Assistant and quickly advanced to the roles of Acting Management Internal Auditor and then Management Internal Auditor, earning a salary of P30,979.00 per month. In January 2011, a company-wide reorganization was approved, leading to all positions being declared vacant. Despite employees’ opposition, including a manifesto from Del Rosario, the reorganization proceeded in June 2011. By October 2012, while on vacation leave, Del Rosario received letters from the petitioner appointing him as a probationary Area Operations Manager, alongside instructions that diminished his previous responsibilities. Although Del Rosario expressed concerns regarding this new position, he accepted it under protest.
Complaint Filed
On January 30, 2013, Del Rosario filed a complaint for illegal dismissal against the petitioner, claiming unlawful demotion and constructive dismissal. He outlined that his former position as Management Internal Auditor had a higher Salary Rank (20 with a salary of Php33,038.05) compared to his new position (Salary Rank 19, Php30,963.95), which also involved fewer responsibilities. Del Rosario contended that the reorganization violated the petitioner’s own guidelines and that he was unjustly denied his original position which was not abolished.
Petitioner’s Explanation
The petitioner defended its actions by citing the need for reorganization in accordance with Republic Act No. 9136 (RA 9136) and guidelines provided by the National Electrification Administration (NEA). They argued that the reorganization was conducted smoothly, resulted in enhanced productivity, and that Del Rosario’s new appointment had not resulted in a decrease in compensation.
Labor Arbiter’s Ruling
On August 29, 2013, the Labor Arbiter dismissed the complaint, asserting that the reorganization was valid and aimed at compliance with NEA policy without evidence of bad faith on the part of the petitioner.
NLRC Ruling
Upon appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s ruling on November 20, 2013, finding that Del Rosario was constructively dismissed as he was appointed to a position that carried a lower salary grade and did not have justifiable cause for not being reinstated to his previous position.
Court of Appeals' Ruling
The Court of Appeals upheld the NLRC’s decision on December 21, 2015, but modified the ruling by deleting the award for salary differential. The petitioner’s motion for reconsideration was subsequently denied on July 7, 2016.
The Present Petition
The petitioner sought to appeal the Court of Appeals’ decisions, reiterating their earlier arguments regarding the legality of the reorganization and the subsequent appointment of Del Rosario.
Issue
The central issue is whether Del Rosario was constructively dismissed when appointed to the new position of Area Operations Management Department Manager, thereby experiencing a demotion in rank, responsibilities, or salary.
Ruling
The Court reaffirmed the principles surrounding management prerogative but highlighted that such power is constrained by the need to ensure justice and fair play. It ruled that Del Rosario indeed faced demotion as his new position involved lesser responsibilities compared to his prior role as Man
...continue readingCase Syllabus (G.R. No. 234812)
Prefatory Remarks
- The Supreme Court acknowledges the rights and privileges of employers but emphasizes that management prerogatives are not absolute.
- The Court has intervened to temper the exercise of management rights when such actions are deemed excessive or unjust.
The Case Overview
- The petition for review on certiorari challenges the Court of Appeals' rulings in CA-G.R. SP No. 134712, which affirmed the National Labor Relations Commission's (NLRC) finding of constructive dismissal of Vicente B. Del Rosario, Jr.
- The review involves a Decision dated December 21, 2015, and a Resolution dated July 7, 2016, both unfavorable to the petitioner, Isabela-I Electric Cooperative, Inc.
Undisputed Facts
- Vicente B. Del Rosario, Jr. was hired as Financial Assistant on January 29, 1996, and was promoted several times, ultimately becoming Management Internal Auditor with a monthly salary of P30,979.00.
- In January 2011, a reorganization plan was approved, leading to the declaration of all positions as vacant, which Del Rosario and other employees opposed.
- Despite opposition, the reorganization proceeded in June 2011, and Del Rosario was later appointed as probationary Area Operations Manager while on vacation in October 2012.
- He received letters instructing him to cease his role as Management Internal Auditor and to turn over his responsibilities to a subordinate.
- Del Rosario expressed concerns about the demotion in a letter but received no response from the company.
The Complaint
- On January 30, 2013, Del Rosario filed a complaint for illegal dismissal, claiming he was construc