GR 76645; (July, 1991) (Digest)
G.R. No. 76645; July 23, 1991
PHILIPPINE TELEGRAPH AND TELEPHONE CORPORATION, petitioner, vs. ALICIA LAPLANA, Hon. RICARDO ENCARNACION, and NATIONAL LABOR RELATIONS COMMISSION, respondents.
FACTS
Alicia Laplana, the cashier of PT&T’s Baguio City branch, was directed in March 1984 to transfer to the Laoag City branch. She refused, citing personal and financial hardships, including being away from her family and the high cost of living. PT&T reiterated the order. When Laplana persisted in her refusal, the company offered her a new assignment in Manila. Laplana declined this as well and instead explicitly requested, via telex and letter, to be retrenched. PT&T subsequently terminated her services on the ground of retrenchment, paid her separation benefits, and had her sign a quitclaim.
Laplana later filed a complaint for illegal dismissal, arguing the transfer was a subterfuge to force her out and that there were no valid grounds for retrenchment. The Labor Arbiter ruled in her favor, a decision affirmed by the NLRC. The NLRC held the transfer was unreasonable and constituted constructive dismissal, ordering her reinstatement with backwages.
ISSUE
Whether the termination of Alicia Laplana’s employment, following her refusal to be transferred and her subsequent request for retrenchment, was legal.
RULING
The Supreme Court granted the petition and reversed the NLRC, declaring the termination legal. The Court emphasized that the employer’s right to transfer personnel is a management prerogative, provided it is exercised in good faith and for legitimate business interests. PT&T’s directive was motivated by operational needs, not by discrimination, bad faith, or an intent to penalize Laplana. The company offered relocation benefits and, upon her refusal of Laoag, an alternative assignment in Manila.
Crucially, Laplana herself proposed the solution of retrenchment. The Court found that when an employee, for legitimate personal reasons, declines a transfer made in good faith by the employer, and voluntarily opts for termination with benefits, such termination is valid. The NLRC erred in substituting its judgment for the employer’s business decision and in disregarding the employee’s own expressed preference for separation. The quitclaim and receipt of benefits further bolstered the conclusion that the termination was a mutual resolution, not an illegal dismissal.