GR 228088; (December, 2019) (Digest)
G.R. No. 228088 , December 04, 2019
Automatic Appliances, Inc., Samson F. Lim, Cornelio P. Buenaventura and Christine M. Pontillas, Petitioners, vs. Francia B. Deguidoy, Respondent.
FACTS
Petitioner Automatic Appliances, Inc. (AAI) hired respondent Francia B. Deguidoy as a regular Sales Coordinator in 1998. In 2013, due to economic difficulties, AAI implemented cost-cutting measures, including branch closures and employee reassignments. Deguidoy was reassigned from the Cubao branch to the Tutuban branch, which she accepted. At Tutuban, Deguidoy failed to meet her sales quota and incurred numerous unexplained absences. Following counseling where Deguidoy cited weight gain as hindering her performance, AAI suggested a lateral transfer to a receptionist or invoicing clerk position, which she refused. AAI later suspended Deguidoy for one month due to attendance infractions and inefficiency. Upon her return on October 7, 2013, AAI verbally informed her of an intended transfer to its Ortigas branch. Deguidoy left work and never returned. AAI sent letters requiring her to explain her absence, which she ignored. Deguidoy filed a complaint for illegal dismissal. The Labor Arbiter dismissed the complaint, finding she was not terminated but was being transferred. The NLRC reversed, holding she was constructively dismissed. The Court of Appeals affirmed the NLRC with modification, ordering reinstatement and backwages.
ISSUE
Whether or not respondent Francia B. Deguidoy was constructively dismissed by petitioners.
RULING
No. The Supreme Court reversed the Court of Appeals and reinstated the Labor Arbiter’s decision, finding no constructive dismissal. The Court held that management enjoys the prerogative to transfer employees and regulate work assignments, provided it is exercised in good faith, does not involve demotion in rank or diminution in pay, and is justified by business exigencies. Deguidoy’s intended transfer to the Ortigas branch was a valid exercise of this prerogative. It was motivated by her documented poor performance and failure to meet sales quotas at her previous assignment, and was aimed at finding a suitable position where she could be productive. The transfer did not involve a demotion or reduction in pay. Her abrupt abandonment of work after being notified of the transfer constituted voluntary resignation. Consequently, she was ordered to return to work, and AAI was ordered to accept her and pay her proportionate 13th month pay for 2013.