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CENTURY CANNING CORPORATION v. CA

FACTS:

Gloria Palad filed a complaint against Century Canning Corporation for illegal dismissal, underpayment of wages, and non-payment of pro-rated 13th month pay. Palad was hired by the company as a fish cleaner and signed an apprenticeship agreement with them. However, a performance evaluation conducted on November 15, 1997, resulted in Palad receiving a rating of "needs improvement" due to her low score, tardiness, and absences. Consequently, Century Canning issued a termination notice to Palad on November 22, 1997.

Palad's complaint was dismissed by the Labor Arbiter for lack of merit, but Century Canning was ordered to pay her last salary and pro-rated 13th month pay. The National Labor Relations Commission affirmed the Labor Arbiter's decision with modification, ordering Century Canning to pay backwages for two months.

However, the Court of Appeals set aside the NLRC decision and ruled that Palad's dismissal was illegal. The court found that the apprenticeship agreement was not valid since it was executed before the TESDA approval of Century Canning's apprenticeship program. Additionally, the court concluded that Palad was not adequately informed of the required standard of performance and was denied due process.

The case raises issues regarding Palad's status as an apprentice and whether Century Canning had valid cause for termination. The Court ultimately ruled that the petition is without merit due to the requirement for the registration and approval of an apprenticeship program before hiring apprentices.

ISSUES:

  1. Whether the Court of Appeals committed a reversible error in holding that the private respondent was not an apprentice.

  2. Whether the Court of Appeals committed a reversible error in holding that the petitioner had not adequately proven the existence of a valid cause in terminating the service of the private respondent.

RULING:

The petition is without merit.

  1. Private Respondent Was Not an Apprentice

    The TESDA's approval of the employer's apprenticeship program is required before the employer is allowed to hire apprentices. Since the apprenticeship agreement was enforced before the TESDA approved petitioner's apprenticeship program, the agreement is void. Therefore, the private respondent is deemed a regular employee, not an apprentice.

  2. Insufficient Proof of Valid Cause for Termination

    The petitioner failed to substantiate its claim that the private respondent was terminated for valid reasons and did not accord the private respondent due process. Thus, the private respondent's termination is deemed illegal.

PRINCIPLES:

  • Apprenticeship Requirements: An apprenticeship agreement is only valid if it is entered into in accordance with a TESDA-approved apprenticeship program.

  • Employer-Employee Relationship: In the absence of TESDA approval, an individual hired under an apprenticeship agreement is considered a regular employee.

  • Just Causes for Termination: Valid dismissal from employment requires proof of just or authorized causes and must follow due process, including the opportunity for the employee to be heard.

  • Burden of Proof: The employer has the burden of proving that termination was for a valid or authorized cause.

  • Due Process: Employees must be notified of their performance evaluations and given the opportunity to improve and defend themselves before termination.