GR 226244; (June, 2021) (Digest)
G.R. No. 226244, June 16, 2021
ANNIEBEL B. YONZON, PETITIONER, VS. COCA-COLA BOTTLERS PHILIPPINES, INC., RESPONDENT.
FACTS
Petitioner Anniebel B. Yonzon was hired by respondent Coca-Cola Bottlers Philippines, Inc. as an HR Generalist on December 1, 2010, but was terminated on April 30, 2011. She filed a complaint for illegal dismissal (first labor case). The NLRC eventually declared her dismissal illegal, ordered her reinstatement as a regular employee, and awarded backwages. Coca-Cola reinstated Yonzon to the position of HR Staff, not HR Generalist. Yonzon filed a Motion for Partial Reconsideration (seeking damages) and a Motion for Execution (seeking reinstatement to her original position and salary adjustment), which remained unacted upon. She then filed a “Third Motion” dated March 14, 2014, asking the NLRC to inquire into the correctness of her reinstatement and to order payment of damages. In this motion, she cited the salaries of four other HR Generalists (her juniors) who were receiving higher pay (ranging from P23,309.00 to P29,193.00) compared to her P18,576.00, to substantiate her claim of discrimination.
On March 21, 2014, Coca-Cola issued a Notice to Explain and placed Yonzon under a 30-day preventive suspension without pay, alleging she violated company rules by her unauthorized disclosure of co-employees’ salaries in her motion before the NLRC. Yonzon explained that the disclosure was made in a pleading filed with the NLRC, not to competitors or third parties. On April 23, 2014, Coca-Cola dismissed Yonzon on grounds of unauthorized disclosure of confidential company information and loss of trust and confidence. Yonzon filed the present complaint for illegal dismissal.
ISSUE
Whether Coca-Cola validly dismissed Yonzon on the ground of loss of trust and confidence for disclosing her co-employees’ salary information in a motion filed with the NLRC.
RULING
No. The Supreme Court ruled that Yonzon was illegally dismissed. The disclosure of salary information in a pleading submitted to the NLRC in connection with a pending labor case does not constitute a breach of trust and confidence warranting dismissal. The Court found that Coca-Cola’s company rule (Rule 3, Section 31 of the Red Book) prohibiting disclosure of “classified/restricted/confidential information” was too generic and vague, as it did not specify that employee salaries were considered such confidential information. The salaries of rank-and-file employees are not trade secrets or confidential business information the disclosure of which would be detrimental to the employer. Yonzon’s act was done in the pursuit of her rights in a labor case and was not shown to have been disclosed to competitors or the public. Therefore, Coca-Cola did not have a valid basis to lose trust and confidence in her. The Supreme Court reversed the Court of Appeals and reinstated the NLRC Decision with modification, declaring the dismissal illegal and awarding Yonzon separation pay in lieu of reinstatement, backwages, and attorney’s fees.
