G.R. No. 226240 . March 06, 2019
MYRA M. MORAL, PETITIONER, V. MOMENTUM PROPERTIES MANAGEMENT CORPORATION, RESPONDENT.

FACTS

Petitioner Myra M. Moral was hired as a probationary Leasing Assistant by respondent Momentum Properties Management Corporation on June 26, 2013. On December 27, 2013, she was informed of her dismissal and advised not to report for work. She filed a complaint for illegal dismissal, alleging that her termination was without notice or just cause, violating both substantive and procedural due process. Respondent countered that Moral was validly terminated for failing to meet performance standards required for regularization. It presented evidence of her below-average scores in administered examinations and poor performance evaluations. Respondent further claimed that after these evaluations, Moral abandoned her work starting December 27, 2013, and failed to respond to invitations for discussion, leading to the issuance of a Notice of Absence Without Official Leave.
The Labor Arbiter ruled in favor of Moral, finding her dismissal illegal and awarding backwages, separation pay, and damages. The NLRC reversed this decision, dismissing the complaint for lack of merit. The Court of Appeals affirmed the NLRC, holding that Moral was validly dismissed as a probationary employee who failed to meet the reasonable standards for regularization.

ISSUE

Whether the Court of Appeals erred in ruling that petitioner was validly dismissed from her employment.

RULING

The Supreme Court denied the petition and affirmed the appellate court’s decision. The legal logic centered on the nature of probationary employment and the employer’s prerogative to set reasonable standards. A probationary employee may be terminated for a just cause or, as in this case, for failing to qualify as a regular employee based on reasonable standards made known at the time of engagement. The Court found that respondent had established, through clear and documented performance evaluations, that petitioner did not meet the prescribed standards for regularization. Her below-average ratings in both examinations and qualitative assessments provided a valid substantive basis for her termination.
Regarding procedural due process, the Court applied the doctrine from Agabon v. NLRC. It found that while respondent had a valid cause for termination, it failed to comply with the twin-notice requirement. Petitioner was not formally notified of the specific performance deficiencies or given a genuine opportunity to explain. Consequently, the dismissal was deemed valid but procedurally infirm. As a remedy for this procedural lapse, and not as compensation for illegal dismissal, the Court awarded nominal damages in the amount of Thirty Thousand Pesos (P30,000.00) to petitioner. The award of full backwages and separation pay was denied, as the dismissal was for a lawful cause. The decision underscores that while employers must strictly observe due process, the failure to do so does not automatically convert a dismissal for a just or authorized cause into an illegal one, provided nominal damages are awarded for the procedural violation.