G.R. No. 228357 , April 16, 2024
C.P. REYES HOSPITAL AND ANGELINE M. REYES, PETITIONERS, VS. GERALDINE M. BARBOSA, RESPONDENT.

FACTS

Respondent Geraldine M. Barbosa was hired by petitioner C.P. Reyes Hospital on a six-month probationary contract from September 4, 2013, to March 4, 2014, for the position of Training Supervisor. The contract required her to maintain a passing score of 80% (Satisfactory), and failure to meet the hospital’s standards could warrant termination. On November 27, 2013, she received a Notice to Explain regarding alleged absences without official leave (AWOL) on November 4, 7, and 8, 2013. She submitted an explanation and supporting documents. On November 29, 2013, she received a termination letter stating she failed to meet reasonable standards due to negative performance feedback on attitude and attendance records, ending her contract on December 30, 2013. Barbosa filed a complaint for illegal dismissal. The Labor Arbiter ruled in her favor, finding illegal dismissal. The National Labor Relations Commission (NLRC) reversed the Labor Arbiter, dismissing the complaint. The Court of Appeals (CA) then reversed the NLRC, reinstating the finding of illegal dismissal with modified awards. Petitioners assailed the CA Decision before the Supreme Court.

ISSUE

Whether the Court of Appeals correctly found that the NLRC committed grave abuse of discretion and correctly declared respondent Geraldine M. Barbosa to have been illegally dismissed.

RULING

The Supreme Court DENIED the petition, affirming the CA’s finding that the NLRC committed grave abuse of discretion and that Barbosa was illegally dismissed. The Court held that as a probationary employee, Barbosa was entitled to security of tenure and could only be terminated for just cause or for failing to meet reasonable standards made known to her at the time of engagement. The termination was invalid because: (1) the hospital deviated from its own evaluation policy by terminating her just two months into her six-month probation, precluding a fair assessment; (2) her performance ratings were “Satisfactory” (passing), and the general negative feedback from evaluators, unsupported by specific incidents or proof that standards were communicated, was insufficient to establish failure to meet standards; and (3) her absences were either authorized, supported by medical certificates, or not habitual to constitute gross neglect. The CA correctly awarded backwages from the date of illegal dismissal until finality of the decision, with legal interest.