G.R. No. 83751 September 29, 1989
MANILA ELECTRIC COMPANY, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION & RAMON L. MERIS, respondents.

FACTS

Ramon L. Meris was hired by Manila Electric Company (Meralco) as a probationary employee for five months starting November 17, 1986, under a probationary employment agreement. His role was as a messenger in the legal department. On March 23, 1987, after approximately four months, Meralco terminated his probationary employment effective immediately via a memorandum. Meralco’s defense was that Meris failed to meet the reasonable performance standards for regularization, citing specific instances of neglect. These included the dismissal of a company civil case due to his failure to pay a sheriff’s fee, late deliveries of vital documents, disobedience to instructions, inefficient work performance, unauthorized use of taxis, and disrespectful conduct.
Meris filed a complaint for illegal dismissal. The Labor Arbiter ruled in his favor, ordering his reinstatement as a regular employee with six months’ backwages. The National Labor Relations Commission (NLRC) affirmed the finding of illegal dismissal but modified the order, directing Meralco to reinstate Meris as a probationary employee for a period of five months with limited backwages. The NLRC emphasized that Meris was terminated without being furnished a written notice of the causes and without being given an opportunity to be heard, constituting a denial of due process.

ISSUE

Whether the termination of a probationary employee for alleged failure to meet performance standards is valid despite non-compliance with procedural due process requirements.

RULING

The Supreme Court granted Meralco’s petition, setting aside the NLRC’s reinstatement order. The Court held that the termination was for a valid cause. A probationary employee may be dismissed for a just cause or when he fails to qualify as a regular employee according to reasonable standards made known at the time of engagement. The factual findings of the Labor Arbiter and NLRC themselves established that Meris’s superiors were dissatisfied with his performance, citing neglect, disobedience, and poor work habits. The legal standard does not require a probationary employee to serve the full six-month maximum period under Article 280 of the Labor Code; an employer may dismiss for cause at any time before the expiration of six months if the employee is found unfit.
However, the Court found Meralco liable for violating procedural due process. The company failed to apprise Meris of the charges against him and to conduct an administrative investigation where he could defend himself prior to termination. This procedural lapse, while not invalidating the dismissal based on substantive grounds, entitled Meris to indemnity. Following the precedent in Wenphil Corp. vs. NLRC, the Court ordered Meralco to pay Meris indemnity in the amount of P1,000.00 as damages for the procedural violation. Thus, the dismissal was substantively justified but procedurally defective.