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 as a Training Supervisor under a six-month probationary employment contract from September 4, 2013, to March 4, 2014. Her contract stipulated she must maintain an average passing score of 80% in performance evaluations as a reasonable standard for regularization. On November 27, 2013, she received a notice to explain absences without official leave. She submitted explanations and supporting documents. On November 29, 2013, she received a termination letter effective December 30, 2013, for allegedly failing to meet the Hospital’s reasonable standards. Her average evaluation scores were 81.68% for the first month and 82.59% for the second month. The Labor Arbiter ruled she was illegally dismissed. The NLRC reversed this, but the Court of Appeals reinstated the Labor Arbiter’s ruling with modifications on monetary awards. The Hospital elevated the case via a Rule 45 Petition.

ISSUE

Whether the termination of Geraldine M. Barbosa’s probationary employment was valid.

RULING

No, the termination was not valid; it constituted illegal dismissal. The Supreme Court affirmed the CA ruling, finding the NLRC committed grave abuse of discretion. Barbosa, as a probationary employee, could only be dismissed for just or authorized cause, or for failure to meet reasonable regularization standards made known at the time of engagement. The records showed she met the communicated standard of an 80% average score. The Hospital’s claim of her failure to meet standards, based on the Nursing Director’s feedback, was executed only after her termination and thus an afterthought. The claim of absenteeism was unsupported, as only one absence was unexplained and no notice to explain was issued for it. Consequently, there was no valid ground for termination. As to monetary awards, the Court ruled that illegally dismissed probationary employees are entitled to backwages computed from the time compensation was withheld until the finality of the decision, and to separation pay in lieu of reinstatement.