Case Summary (G.R. No. 122866)
Dismissal and Initial Labor Arbiter Decision
The dismissal letter dated September 14, 1992, cited Nath's absence and lack of communication as grounds for her termination. Labor Arbiter Ramon Valentin C. Reyes ruled in favor of Nath, declaring her dismissal illegal due to insufficient justification and a failure to adhere to due process, thus ordering her reinstatement and awarding back wages, moral damages, exemplary damages, and attorney’s fees.
NLRC Ruling and Appeal
The National Labor Relations Commission (NLRC) later reversed this decision, dismissing the complaint for lack of merit but ordered the hotel to pay Nath her salaries and related benefits for three additional months of her probation, recognizing non-compliance with due process but allowing for dismissal on just cause due to her performance issues. This prompted Nath to petition for certiorari to challenge the NLRC's ruling.
Grounds for Petition and Due Process
Nath's petition asserted that the NLRC committed grave abuse of discretion by upholding her dismissal without due process and contending that her performance was not sufficiently documented as substandard prior to termination. The court acknowledged that due process had not been fully adhered to, specifically the lack of two written notices that outline the reasons for dismissal.
Just Cause for Dismissal
Despite the procedural deficiencies in the dismissal process, the court recognized that Nath's employment could be terminated on just cause. Article 281 of the Labor Code stipulates that probationary employees can be dismissed for just causes or failure to meet reasonable standards. Evidence was brought forth by Shangri-La regarding Nath's inadequate work performance, including her failure to complete tasks and disregard for company policies, which justified her dismissal.
Conclusion and Affirmation of NLRC D
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Case Background
- On June 1, 1992, Melva Nath commenced employment with Shangri-La Hotel Manila as Director of Rooms under a probationary period of six months.
- A performance evaluation meeting took place on September 4, 1992, during which Resident Manager Gerard Sintes informed Nath of her poor work performance and non-compliance with company rules.
- Nath did not dispute Sintes’ assessment nor provide justifications for her performance issues.
Absence and Dismissal
- Nath called in sick on September 7, 1992, and failed to report to work on September 9.
- Personnel Manager Teresa Lalin and Sales Director Gami Holazo visited Nath on September 9 to remind her of her obligations and the upcoming evaluation on September 11.
- On September 10, Nath sent a letter expressing her concerns regarding her performance evaluation and requested a copy before returning to work. She attached documentation of her accomplishments during her probation.
- Nath was dismissed on September 14, 1992, via a letter citing her absence and failure to report for work as grounds for her termination.
Legal Proceedings
- Nath filed a complaint for illegal dismissal, which was initially upheld by Labor Arbiter Ramon Valentin C. Reyes, who ruled her