G.R. No. L-56633 April 24, 1985
MEDICAL DOCTORS, INC. (MAKATI MEDICAL CENTER), petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, LABOR ARBITER CONRADO MAGLAYA and EVELYN ELONA, respondents.

FACTS

Private respondent Evelyn Elona was hired by petitioner Makati Medical Center under a six-month probationary appointment from July 16, 1975, to January 15, 1976, as a clerk in its Out-Patient Charity Department. Her appointment stipulated that her employment could be terminated if her services were judged unsatisfactory. Near the end of her probation, an allegation surfaced that she had borrowed money from a patient, Mrs. Leticia Lavapiez. An investigation was initiated, and her probationary period was extended by one month, until February 14, 1976, pending the inquiry. On February 13, 1976, the hospital terminated her employment, effective the following day, stating she had “not measured up to the requirement of this department.”

ISSUE

The core issue is whether the dismissal of a probationary employee for borrowing money from a patient, which was later repaid, constitutes a valid termination based on failure to meet the employer’s reasonable standards.

RULING

The Supreme Court ruled in favor of the petitioner and reversed the decisions of the Labor Arbiter and the NLRC. The legal logic centers on the nature of probationary employment and the employer’s prerogative to set standards for regularization. The Court held that a probationary employee, like Elona, does not enjoy the full security of tenure of a regular employee. The employer retains the right to assess whether the employee has met the prescribed reasonable standards for permanent employment. The act of borrowing money from a patient, while perhaps not inherently dishonest or illegal, could reasonably be viewed by a hospital management as conduct unbecoming and contrary to institutional policy, especially within a charity department serving indigents. This act provided a factual basis for the employer to determine that Elona failed to meet its standards of conduct and fitness for the role. The Court found the NLRC and Labor Arbiter had substituted their own judgment for that of the employer regarding the sufficiency of the cause for termination, which was a reversible error. The termination occurred within the extended probationary period, and the employer’s decision that she did not qualify for regular status was a valid exercise of management prerogative, absent a showing of illegality, bad faith, or discrimination. Therefore, her dismissal was legal.