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ABBOTT LABORATORIES v. PEARLIE ANN F. ALCARAZ

FACTS:

The case involves a labor dispute between the petitioner, Abbott Laboratories Philippines, and the respondent, Pearlie Ann F. Alcaraz. Alcaraz applied for a position at Abbott and was accepted on a probationary basis. She was given an orientation and provided with information regarding her duties and responsibilities. The evaluation of probationary employees was to be done at the third and fifth month of employment.

During her employment, Alcaraz noticed disciplinary problems among the staff and reprimanded them. However, her management style was deemed "too strict" by her supervisor. Alcaraz expressed her concerns to another employee, who assured her that the Human Resources Department would support her decisions.

On April 12, 2005, Alcaraz received an email requesting action on the staff's performance evaluation. She submitted the evaluation. During a meeting on April 20, 2005, Alcaraz accidentally saw an email questioning her job performance. She asked the HR Director if this was the normal evaluation process, to which she responded that it was not.

On May 16, 2005, Alcaraz was informed that she failed to meet the standards for regularization and was requested to resign. She asked for one week to decide but was not given time. The next day, it was announced to the entire staff that Alcaraz had resigned due to health reasons, although she had only requested leave for that day. On May 23, 2005, Alcaraz was handed a termination letter with reasons for her dismissal.

Feeling unjustly terminated, Alcaraz filed a complaint for illegal dismissal and damages against Abbott. The Labor Arbiter dismissed her complaint, but the National Labor Relations Commission ruled in her favor, ordering her reinstatement and the payment of backwages.

The petitioners filed a motion for reconsideration, which was denied by the NLRC. They then filed a Petition for Certiorari before the Court of Appeals, which affirmed the NLRC's decision. Meanwhile, Alcaraz moved for the execution of the NLRC's decision, which was initially denied but eventually reversed by the NLRC. Petitioners filed another Petition for Certiorari before the CA, challenging the execution of the NLRC decision.

The CA ruled in favor of Alcaraz, affirming the execution of the NLRC's decision. Petitioners filed a motion for reconsideration, which was still pending when Alcaraz again moved for execution before the Labor Arbiter. Petitioners appealed the LA's order to the NLRC.

While the motion for reconsideration of the CA's ruling was pending, Alcaraz alleged forum shopping by the petitioners. Alcaraz also argued that the petitioners failed to comply with the certification requirement in the instant petition.

ISSUES:

  1. Whether or not Alcaraz was sufficiently informed of the reasonable standards to qualify her as a regular employee.

  2. Whether or not Alcaraz was validly terminated from her employment.

  3. Whether or not the individual petitioners herein are liable.

RULING:

  1. Alcaraz was sufficiently informed of the reasonable standards to qualify her as a regular employee. The Supreme Court found ample evidence that Alcaraz was apprised of the regularization standards prior to, during, and after her engagement, such as being informed of her duties and responsibilities, receiving training and evaluation modules, and having an extensive background relevant to her job.

  2. Alcaraz was validly terminated from her employment based on the failure to meet the standards required for regularization. The Court ruled that her non-regularization was justified given the documented deficiencies in her performance.

  3. The individual petitioners are not liable. There was no evidence that the individual petitioners acted in bad faith or with gross negligence in terminating Alcaraz's employment.

PRINCIPLES:

  1. Probationary Employment and Standards Communication An employer must communicate the regularization standards to the probationary employee at the time of the engagement. Failure to do so results in the employee being considered a regular employee.

  2. Termination Procedures for Probationary Employees Termination of a probationary employee for failure to meet standards only requires written notice served within a reasonable time from the effective date of termination.

  3. Employer's Contractual Obligation Employers are bound by their own company policies which create contractual obligations. Breaches of such policies, even if procedural, can warrant the payment of nominal damages.

  4. Personal Liability of Corporate Officers Liability attaches to corporate officers only if they consent to a patently unlawful act, are guilty of bad faith or gross negligence, or are made liable by specific provision of law. Bad faith cannot be presumed and must be proven.