G.R. No. 100641 June 14, 1993
Farle P. Almodiel, petitioner, vs. National Labor Relations Commission (First Division) and Raytheon Phils., Inc., respondents.

FACTS

Petitioner Farle P. Almodiel, a Certified Public Accountant, was hired in October 1987 as Cost Accounting Manager by respondent Raytheon Philippines, Inc., with a starting monthly salary of P18,000.00. He was later regularized and received salary increases. On January 27, 1989, he was informed by management that his position was being abolished on the ground of redundancy. He pleaded for deferment or transfer to another department but was told the decision was final. Consequently, he filed a complaint for illegal dismissal. The Labor Arbiter ruled in his favor, declaring the termination illegal and ordering his reinstatement with full backwages, moral and exemplary damages, and attorney’s fees. On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision, upheld the termination on the ground of redundancy, and ordered the payment of P100,000.00 as separation pay/financial assistance. Petitioner then filed this petition for certiorari, alleging grave abuse of discretion by the NLRC and claiming his termination was tainted with malice, bad faith, and irregularity. He argued that his functions were absorbed by the Payroll/MIS/Finance Department under Danny Ang Tan Chai, a resident alien, and that he was better qualified for that managerial position.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in upholding the termination of petitioner’s employment on the ground of redundancy.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion on the part of the NLRC. The Court ruled that the termination was anchored on a valid and authorized cause under Article 283 of the Labor Code. The determination of redundancy is a management prerogative, and the courts will not interfere with such business judgment absent a showing of violation of law, or arbitrary or malicious action. The Court held that even if the functions of the abolished position were merely transferred or absorbed by another, no malice or bad faith could be imputed, as an employer has no legal obligation to keep more employees than are necessary. The Court also found no merit in petitioner’s claim that he was better qualified than Ang Tan Chai to head the department that allegedly absorbed his functions, stating that the assessment of employee qualifications and fitness is an exclusive prerogative of management. The NLRC’s decision was affirmed.