GR 218282; (September, 2020) (Digest)
G.R. No. 218282 , September 09, 2020
REDENTOR Y. AGUSTIN, PETITIONER, VS. ALPHALAND CORPORATION, ET AL., RESPONDENTS.
FACTS
Petitioner Redentor Agustin was hired by respondent Alphaland Corporation as an Executive Chef under a six-month probationary period. His employment contract, via a letter-offer, stated he was expected to render the highest quality of professional service and pursue the company’s interests. Barely four months into his employment, Agustin received a notice of termination effective immediately, stating he failed to meet the company’s standards for regularization. Agustin filed a complaint for illegal dismissal, alleging the specific standards for regularization were never made known to him.
The Labor Arbiter ruled in Agustin’s favor, finding the standard in the appointment letter too general. The National Labor Relations Commission affirmed, noting Alphaland failed to prove Agustin was properly apprised of reasonable, specific performance standards. The Court of Appeals denied Alphaland’s petition, upholding the findings of illegal dismissal.
ISSUE
Whether Agustin was illegally dismissed as a probationary employee.
RULING
Yes, Agustin was illegally dismissed. The Supreme Court affirmed the lower tribunals’ findings. For a valid termination of a probationary employee based on failure to meet standards, the employer must prove two elements: first, that the employee was apprised of such reasonable standards at the start of the probation; and second, that the dismissal was for a just or authorized cause. The legal logic hinges on the fundamental requirement of due process, which begins with notice of what is expected.
Here, the standard in the contract—”render the highest quality of professional service”—was deemed too general and vague. It failed to specify concrete, measurable criteria against which Agustin’s performance as an Executive Chef could be fairly assessed. Alphaland’s belated submission of affidavits on appeal, claiming guest dissatisfaction, did not cure this fatal defect, as these standards were not communicated to Agustin beforehand. Consequently, his termination for allegedly failing to meet these unspecified standards was invalid. The Court modified the award, granting Agustin full backwages and separation pay in lieu of reinstatement, as the probationary period had long expired, making reinstatement impracticable.