GR 99039; (February, 1997) (Digest)
G.R. No. 99039 February 3, 1997
FORD PHILIPPINES, INC., JOHN SAGOVAC and ANASTACIO R. TEODORO, II, petitioners, vs. COURT OF APPEALS and MANUEL I. OBOZA, respondents.
FACTS
Manuel I. Oboza was employed by Ford Philippines, Inc. from 1968 until 1983, eventually rising to the position of General Sales Manager. In December 1982, Ford informed Oboza that his position was declared redundant and would be abolished. He was offered two alternatives: accept redundancy with full benefits or accept a reappointment to his former position of Vehicle Sales Manager. Oboza did not formally respond, and Ford subsequently terminated his employment on the ground of redundancy effective January 15, 1983.
Oboza later discovered that prior to his termination, Ford had filed an appeal with the Department of Labor and Employment seeking an extension of the alien employment permit for Malcolm J. Johnston, the Director of Sales and Marketing and Oboza’s immediate superior. In that appeal, Ford stated that Oboza, who was being groomed as Johnston’s replacement, had failed to develop the proper attitude and qualities required for the higher position after over eighteen months of training. Oboza then filed an action for damages against Ford and its officers, alleging that the abolition of his position was done in bad faith to support the company’s appeal for Johnston’s permit and that the statements in the appeal were defamatory.
ISSUE
Whether the petitioners are liable for damages arising from the termination of Oboza’s employment and the statements made in their appeal to the DOLE.
RULING
The Supreme Court ruled in favor of the petitioners, reversing the Court of Appeals. On the termination, the Court held that redundancy is a recognized authorized cause for dismissal under the Labor Code and a legitimate exercise of management prerogative. The redundancy was established in good faith, as Oboza’s functions as General Sales Manager were admittedly similar to those of Johnston, making the position superfluous. The offer of an alternative position negated any claim of bad faith in the dismissal itself.
Regarding the statements in the DOLE appeal, the Court ruled they were absolutely privileged communications. The appeal was a pleading submitted in an official quasi-judicial proceeding before the DOLE. Statements made in the course of judicial or official proceedings are privileged, as long as they are relevant to the subject of inquiry. The statements concerning Oboza’s qualifications were directly pertinent to Ford’s argument for retaining Johnston and thus fell within this privilege. Consequently, no cause of action for damages based on these statements could prosper. The trial court’s decision dismissing Oboza’s complaint was reinstated.