G.R. No. 199469 & G.R. No. 199505, September 11, 2019
Gertrudes D. Mejila, Petitioner, vs. Wrigley Philippines, Inc., Jesselyn P. Panis, et al., Respondents. / Wrigley Philippines, Inc., Petitioner, vs. Gertrudes D. Mejila, Respondent.

FACTS

Wrigley Philippines, Inc. (WPI), a chewing gum manufacturer, employed Gertrudes D. Mejila as an occupational health nurse, regularizing her in 2007. On October 26, 2007, WPI informed Mejila that her position was abolished due to a manpower rationalization program (Headcount Optimization Program) aimed at cost efficiency, as clinic management was not integral to its core business. Her termination was effective November 26, 2007, but she was paid until then and not required to work after October 26. WPI notified the DOLE Rizal Field Office of the termination and offered separation benefits. WPI outsourced clinic services to Activeone Health, Inc. Mejila filed an illegal dismissal complaint. The Labor Arbiter ruled in her favor, citing procedural defects and finding the outsourcing more expensive. The NLRC reversed, upholding the redundancy dismissal and finding cost savings. The Court of Appeals affirmed the redundancy but found WPI failed to properly serve the termination notice to the DOLE Regional Office, awarding Mejila nominal damages and attorney’s fees. Both parties filed petitions: Mejila challenged the finding of authorized cause, and WPI challenged the due process finding.

ISSUE

1. Whether WPI validly dismissed Mejila on the ground of redundancy.
2. Whether WPI complied with procedural due process requirements for termination.

RULING

1. Yes, the dismissal was valid due to redundancy. Redundancy exists when an employee’s services exceed what is reasonably demanded by the enterprise. The determination is a management prerogative, subject to judicial review only for violations of law or arbitrary/malicious acts. WPI substantiated its Headcount Optimization Program with evidence of deliberation, business projections, and cost savings computations. The decision to outsource non-core clinic operations was a legitimate business judgment to improve efficiency. Mejila failed to prove bad faith, as the program affected multiple employees and was implemented prior to her termination. The outsourcing resulted in overall cost savings when considering the total compensation package of in-house staff versus service fees.
2. No, WPI failed to comply with procedural due process. The law requires serving a written notice of termination to the DOLE Regional Office at least one month before the intended date. WPI only notified the DOLE Rizal Field Office, a satellite office, and the Regional Director certified non-receipt. This constitutes a violation of the procedural requirement. However, this defect does not invalidate the dismissal for an authorized cause but warrants an award of nominal damages for the violation of statutory due process.
The Supreme Court denied both petitions, affirming the Court of Appeals’ Decision. The dismissal based on redundancy was upheld as a valid exercise of management prerogative. The procedural due process violation was confirmed, sustaining the award of nominal damages and attorney’s fees to Mejila.