G.R. No. 97067 September 26, 1996
HOMEOWNERS SAVINGS AND LOAN ASSOCIATION, INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and MARILYN CABATBAT, respondents.

FACTS

Private respondent Marilyn Cabatbat, a CPA, was employed as a Branch Accountant by petitioner Homeowners Savings and Loan Association. On September 14, 1984, management issued a memorandum announcing the transfer of several employees, including Cabatbat, from San Carlos City to Urdaneta, both in Pangasinan, to uplift operational efficiency. The transfer was deferred due to her pregnancy. After giving birth, she was ordered to report to Urdaneta in February 1985. Cabatbat refused, citing personal reasons, including additional expenses and distance. The petitioner issued multiple memoranda, offered transportation reimbursement, and gave her opportunities to explain her refusal, culminating in a show-cause notice. Cabatbat persistently reported to her old branch. Consequently, she was terminated for willful disobedience on March 14, 1985.
Cabatbat filed a complaint for illegal dismissal. The Labor Arbiter dismissed her complaint, but the NLRC reversed, finding the dismissal illegal. The NLRC held the transfer constituted a constructive dismissal as it was unreasonable and imposed undue hardship. The employer elevated the case to the Supreme Court via certiorari.

ISSUE

Whether the dismissal of Marilyn Cabatbat for willful disobedience of a lawful transfer order was valid.

RULING

Yes, the dismissal was valid. The Supreme Court granted the petition, reinstating the Labor Arbiter’s decision. The transfer was a valid exercise of management prerogative, motivated by legitimate business needs to improve the operational efficiency of the Urdaneta branch. The order was lawful, reasonable, and made in good faith. The new assignment was within the same province, did not entail a demotion or reduction in pay, and the employer even offered transportation reimbursement to mitigate any inconvenience.
Cabatbat’s outright and persistent refusal to comply, despite repeated directives and warnings, constituted willful disobedience under Article 282 of the Labor Code. The Court emphasized that while the Constitution protects labor, it also recognizes the rights of management. The employer acted with patience, accorded Cabatbat ample procedural due process through written exchanges, and her termination was a last resort. Her dismissal was for a just cause and effected with due process. The law does not authorize the oppression of the employer, and an employee’s defiance of a lawful order warrants termination.