Jaso v. Metrobank & Trust
REITERATIONFacts
The Antecedents: Petitioner Karen G. Jaso was hired by Metrobank & Trust Co. (Metrobank) as a Management Trainee on July 16, 2012. On January 2, 2013, she received a Show Cause Order charging her with gross and habitual negligence, unprofessional behavior, unauthorized absences, non-disclosure of material information, and dishonesty. Petitioner refuted these charges in a letter dated January 9, 2013. Subsequently, on January 14, 2013, Metrobank issued a letter dismissing her from employment effective January 15, 2013. Petitioner contended that her termination was unjust, invalid, and lacked due process, asserting she had become a regular employee after six months of service. Procedural History: Petitioner filed a complaint for illegal dismissal against Metrobank and its officers. The Labor Arbiter (LA) ruled in favor of the petitioner, ordering reinstatement and backwages, finding that her probationary employment had expired before her dismissal. Metrobank appealed to the National Labor Relations Commission (NLRC), which reversed the LA's decision, finding that petitioner was validly dismissed during her probationary period. The NLRC held that Metrobank had complied with due process and that petitioner failed to meet the regularization standards. Petitioner then filed a Petition for Certiorari with the Court of Appeals (CA), which affirmed the NLRC's ruling, finding no grave abuse of discretion. The CA concluded that Metrobank had substantially complied with the rule on notification of standards and that petitioner's termination was valid. The Petition: Petitioner filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's decision. She argues that the CA erred in ruling that her probationary employment was validly terminated due to her failure to qualify as a regular employee. Petitioner claims Metrobank presented no proof of the alleged performance standards and that she was not apprised of any performance criteria at the time of her engagement. She further contends that her termination was baseless due to a lack of proof of the infractions she allegedly committed. The core of her argument is that the CA erroneously upheld the NLRC's finding of valid termination, thereby denying her claim of illegal dismissal.
Issue(s)
Whether petitioner was validly dismissed from probationary employment. Whether petitioner was sufficiently apprised of the standards for regularization. Whether petitioner was still a probationary employee at the time of her termination.
Ruling
The petition is denied. The Court of Appeals Decision affirming the NLRC ruling that petitioner was validly dismissed is affirmed. The termination of petitioner's employment was valid and considered Metrobank's exercise of management prerogative.
Ratio Decidendi
On the issue of whether petitioner was validly dismissed from probationary employment: The Court held that petitioner failed to qualify as a regular employee. Her overall performance appraisal rating was 2.21, which is 'Below Meets Standard.' Furthermore, she committed violations by making errors in the 'RF Regularization Evaluation Sheets,' misrepresenting training attendance, and making false allegations about other employees' accountabilities. She also exhibited unprofessional and childish behavior towards her superior and incurred unauthorized absences. These failures, coupled with her performance rating, constituted grounds for termination under Article 296 of the Labor Code, which allows termination for failure to qualify as a regular employee in accordance with reasonable standards made known by the employer. The Court found substantial evidence supporting Metrobank's conclusion that petitioner did not meet the standards for regularization. On the issue of whether petitioner was sufficiently apprised of the standards for regularization: The Court found that petitioner was indeed made aware of the standards. Her probationary employment was for six months, and she acknowledged this status. On July 25, 2012, she received an Orientation Checklist confirming receipt of documents like the Job Description and Performance Appraisal Management System sheet, and attended an orientation where criteria for regularization, including attitude, pro-activeness, ability to work under pressure, and work output quality, were discussed. The Court noted that for a Management Trainee position, informing the employee of their duties and responsibilities, the adequate performance of which is the implied standard for regularization, is sufficient. Metrobank's efforts to apprise petitioner of her job requirements and expectations were deemed reasonable, satisfying the requirement under Section 6(d) of Rule VIII-A of the Implementing Rules and Regulations of the Labor Code. On the issue of whether petitioner was still a probationary employee at the time of her termination: The Court reiterated the ruling in Alcira v. National Labor Relations Commission and CALS Poultry Supply Corp. v. Roco, stating that a six-month probationary period is reckoned from the date of appointment up to the same calendar date of the sixth month following. Petitioner was hired on July 16, 2012, making her probationary period extend until January 16, 2013. Therefore, her termination on January 15, 2013, occurred while she was still a probationary employee. Even assuming, arguendo, that she had become a regular employee, the Court found that Metrobank still validly effected her dismissal by observing the two-notice rule: a Show Cause Letter was issued on January 2, 2013, and a termination notice on January 14, 2013, affording her due process.
Main Doctrine
A probationary employee may be terminated for failure to qualify as a regular employee in accordance with reasonable standards made known by the employer at the time of engagement, provided that the employer has substantially complied with due process requirements.