Flordeliza Maria Reyes-Rayel vs. Philippine Luen Thai Holdings, Et Al. G.R. No. 174893 July 11, 2012 Doctrine

FLORDELIZA MARIA REYES-RAYEL vs.
PHILIPPINE LUEN THAI HOLDINGS, et

al.
G.R. No. 174893
July 11, 2012
Doctrine:
The law is fair and just to both labor and management. Thus, while the Constitution accords an
employee security or tenure, it abhors oppression to an employer who cannot be compelled to
retain an employee whose continued employment would be patently inimical to its interest.
Facts:
PLTHC hired petitioner as Corporate Human Resources (CHR) Director for Manufacturing for
its subsidiary/affiliate company, L&T. Subsequently, Petitioner received a Prerequisite
Notice saying that she failed to perform in accordance with management directives in various
instances, which collectively have resulted in loss of confidence in her capability to promote the
interests of the Company. In a Termination Notice, respondents dismissed petitioner from the
service for loss of confidence on her ability to promote the interests of the company. This led
petitioner to file a Complaintfor illegal dismissal, payment of separation pay, 13 month pay,
moral and exemplary damages, attorney’s fees, and other unpaid company benefits against
respondents and its officers, namely, Sauceda, Edles and Willie.
Petitioner argued that her dismissal was without valid or just cause and was effected without due
process. According to her, the causes for her dismissal as stated in the Prerequisite Notice and
Notice of Termination are not proper grounds for termination under the Labor Code and the
same do not even pertain to any willful violation of the company’s code of discipline or any
other company policy. She likewise claimed that due process was not observed since she was not
afforded a hearing, investigation and right to appeal as per company procedure for disciplining
employees. Respondents, on the other hand, claimed that they have a wide discretion in
dismissing petitioner as she was occupying a managerial position. Respondents, on the other
hand, claimed that they have a wide discretion in dismissing petitioner as she was occupying a
managerial position. Also, petitioner was accorded due process as she was furnished with two
notices - the first requiring her to explain why she should not be terminated, and the second
apprising her of the management’s decision to terminate her from employment.
Issue:
Whether or not petitioner was illegally dismissed from her employment by respondents
Ruling:
The petition is devoid of merit.
Jurisprudence provides that an employer has a distinct prerogative and wider latitude of
discretion in dismissing a managerial personnel who performs functions which by their nature
require the employer’s full trust and confidence. As distinguished from a rank and file personnel,
mere existence of a basis for believing that a managerial employee has breached the trust of the
employer justifies dismissal. Loss of confidence as a ground for dismissal does not require proof
beyond reasonable doubt as the law requires only that there be at least some basis to justify it."
Petitioner, in the present case, was L&T’s CHR Director for Manufacturing. As such, she was
directly responsible for managing her own departmental staff and is therefore considered in a
managerial position. However, petitioner delivered dismal performance and displayed poor work
attitude which constitute sufficient reasons for an employer to terminate an employee on the
ground of loss of trust and confidence.
The Court is convinced that respondents have sufficient and valid reasons in terminating the
services of petitioner as her continued employment would be patently inimical to respondents’
interest. An employer "has the right to regulate, according to its discretion and best judgment, all
aspects of employment, including work assignment, working methods, processes to be followed,
working regulations, transfer of employees, work supervision, lay-off of workers and the
discipline, dismissal and recall of workers."

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Flordeliza Maria Reyes-Rayel vs. Philippine Luen Thai Holdings, Et Al. G.R. No. 174893 July 11, 2012 Doctrine

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FLORDELIZA MARIA REYES-RAYEL vs.

PHILIPPINE LUEN THAI HOLDINGS, et

The petition is devoid of merit.

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