GR 169967; (November, 2016) (Digest)
G.R. No. 169967 , G.R. No. 176074, G.R. No. 176205, November 23, 2016
COCA-COLA BOTTLERS PHILS., INC., EMMANUEL CURA, ANGEL LABAO, ALMEDO LOPEZ, and RUSTOM ALEJANDRINO, Petitioners, vs. IBM LOCAL I, REGNER SANGALANG and ROLANDO NACPIL, Respondents. / REGNER A. SANGALANG and ROLANDO V. NACPIL, Petitioners, vs. COCA-COLA BOTTLERS PHILS., INC. (CCBPI), EMMANUEL CURA, ANGEL LABAO, and RUSTOM ALEJANDRINO, Respondents. / COCA-COLA BOTTLERS PHILS., INC., EMMANUEL CURA, ANGEL LABAO, and RUSTOM ALEJANDRINO, Petitioners, vs. REGNER A. SANGALANG and ROLANDO NACPIL, Respondents.
FACTS
Regner A. Sangalang and Rolando Nacpil were assistant syrupmen at Coca-Cola Bottlers Philippines, Inc. (CCBPI). In July 2000, CCBPI management decided to revert the duty of dumping caps/crowns to the assistant syrupmen, a task that had been assigned to utility men and later to independent contractors in their plant since 1982. The employees expressed concerns and suggested regularizing the contractual workers instead. After meetings and a dry run, CCBPI issued a schedule for the dumping activity. On August 21, 22, 23, and 24, 2000, Sangalang and Nacpil refused to perform the dumping task, asserting it was not part of their responsibilities. CCBPI issued multiple Notices to Explain for insubordination under its Code of Discipline, placed them under preventive suspension, and conducted an investigation. On September 22, 2000, CCBPI found them guilty and dismissed them. The complainants filed a case for illegal dismissal.
ISSUE
Whether the dismissal of Sangalang and Nacpil was legal, i.e., whether their refusal to perform the dumping of caps/crowns constituted willful disobedience or insubordination justifying termination under Article 282 of the Labor Code.
RULING
The Supreme Court ruled that the dismissal was illegal. For willful disobedience to be a valid cause for dismissal, the employer’s order must be reasonable, lawful, made known to the employee, and pertain to the duties which the employee has been engaged to discharge. The Court found that the order to dump caps/crowns was unreasonable. The duty was not among the listed duties and responsibilities of an assistant syrupman in the company’s job description. While management has the prerogative to assign additional duties, such assignment must be reasonable and not constitute a demotion, promotion, or a significant change in job nature. The task of dumping caps/crowns was menial, manual, and unrelated to the technical and skilled functions of an assistant syrupman, which involved syrup preparation and equipment maintenance. The fact that the task had been performed by utility men and independent contractors for 18 years reinforced the finding that it was not part of the complainants’ regular duties. Therefore, their refusal to obey the unreasonable order was justified and did not constitute willful disobedience warranting dismissal. The Court ordered their reinstatement with full backwages.