G.R. No. 191154 . April 7, 2014
SPI TECHNOLOGIES, INC. and LEA VILLANUEVA, Petitioners, vs. VICTORIA K. MAPUA, Respondent.

FACTS

Victoria K. Mapua was hired in 2003 by SPI Technologies, Inc. (SPI) as the Corporate Development’s Research/Business Intelligence Unit Head and Manager. In August 2006, Elizabeth Nolan was hired as her supervisor. In October 2006, Mapua’s laptop hard disk crashed, causing data loss, which she worked to recover. On November 13, 2006, after retrieving the data, Nolan informed Mapua that her position was being realigned as a subordinate to co-manager Sameer Raina due to missed deadlines and complaints from colleagues about her attendance and work ethic. Mapua disputed these claims with attendance records, but Nolan dismissed the matter.
By December 2006, Mapua’s colleagues began ostracizing her, and Nolan and Raina redistributed about 95% of her duties to rank-and-file staff. Mapua consulted SPI’s Human Resource Director, Lea Villanueva, about a transfer, but an interview for an intra-office opening did not materialize. On February 28, 2007, Mapua saw a new table of organization downgrading her level. On March 21, 2007, Raina informed Mapua via phone that her position was redundant and she was terminated immediately. Villanueva confirmed the termination, and Mapua’s laptop, mobile phone, and office phone were deactivated. Mapua received a termination letter citing redundancy and offering separation pay.
Mapua filed a complaint for illegal dismissal. SPI later sent a second termination letter and a third notice dated March 21, 2007, changing the effectivity date to April 21, 2007. On May 13, 2007, SPI published a recruitment advertisement including a position for Marketing Communications Manager under Corporate Support—Mapua’s former group. Mapua also discovered a job advertisement by Prime Manpower for a Corporate Development Manager, which she suspected was for SPI, and applied under a pseudonym; the consultant allegedly revealed SPI was the client. SPI denied contracting Prime Manpower and claimed the Marketing Communications Manager position was different from Mapua’s. SPI asserted that Mapua’s termination was due to a bona fide reorganization after an assessment showed her duties could be performed by other officers.
The Labor Arbiter (LA) ruled in favor of Mapua, declaring the redundancy without factual basis and awarding backwages, separation pay, moral and exemplary damages, attorney’s fees, and the car assigned to her. The National Labor Relations Commission (NLRC) reversed the LA, finding the termination legal due to management prerogative but ordering payment of separation benefits and final pay. The Court of Appeals (CA) reinstated the LA’s decision, finding the redundancy not proven and the dismissal tainted with bad faith.

ISSUE

Whether Mapua was illegally dismissed on the ground of redundancy.

RULING

Yes, Mapua was illegally dismissed. The Supreme Court affirmed the CA’s decision, with modifications to the awarded damages.
The Court held that while management prerogative includes determining the continuing necessity of a position, it is not absolute and must be exercised in good faith. For a valid redundancy termination, the employer must prove: (1) the redundancy is bona fide, and (2) fair and reasonable criteria were used in selecting the employee for dismissal. SPI failed to substantiate the redundancy claim. The Inter-Office Memorandum cited for reorganization was general and did not specifically declare Mapua’s position redundant. The affidavit by Villanueva claiming Mapua’s functions were being performed by others was self-serving and lacked detail. The recruitment advertisement for a Marketing Communications Manager shortly after Mapua’s dismissal, and the alleged job posting for a Corporate Development Manager through Prime Manpower, undermined SPI’s claim that the position was no longer necessary. The Court found the dismissal was motivated by Mapua’s earlier dispute with Nolan over attendance issues, indicating bad faith.
Thus, the termination was illegal. Mapua was awarded backwages from March 21, 2007 until finality of the decision, separation pay in lieu of reinstatement, moral damages of ₱100,000, exemplary damages of ₱100,000, and attorney’s fees equivalent to 10% of the total monetary award. The order for SPI to award Mapua the company car was deleted, as it was not a demand in her complaint.