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Philippine Span Asia Carriers Corporation vs. Heidi Pelayo

The petitioner Philippine Airlines conducted an investigation into anomalies discovered in its Davao City branch and asked the respondent Heidi Pelayo to come to the main office for an interview to shed light on the issues. Pelayo claimed this was constructive dismissal. The Court ruled that the petitioner was exercising its management prerogative to investigate misdeeds and seek information from involved employees. It does not constitute constructive dismissal for an employer to investigate in this manner or ask employees to cooperate, as long as the employer follows proper procedures and policies.

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168 views1 page

Philippine Span Asia Carriers Corporation vs. Heidi Pelayo

The petitioner Philippine Airlines conducted an investigation into anomalies discovered in its Davao City branch and asked the respondent Heidi Pelayo to come to the main office for an interview to shed light on the issues. Pelayo claimed this was constructive dismissal. The Court ruled that the petitioner was exercising its management prerogative to investigate misdeeds and seek information from involved employees. It does not constitute constructive dismissal for an employer to investigate in this manner or ask employees to cooperate, as long as the employer follows proper procedures and policies.

Uploaded by

Liza Barreto
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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PHILIPPINE SPAN ASIA CARRIERS CORPORATION vs.

HEIDI PELAYO
GR No. 212003 | February 23, 2018 | Leonen, J.

Statement of the issue


Whether the investigation conducted by the petitioner Sulpicio Lines against Private Respondent,
within which the latter was asked to come to the main office for an interview concerning the
anomaly discovered in its Davao Branch, is tantamount to constructive dismissal

Petitioner’s arguments
Peitioner avers that Respondent was merely asked to come to Cebu “to shed light on the
discovered anomalies” in its Davao City branch and was only asked to cooperate in prosecuting
tan and Sobiaco.

Respondent’s Arguments
Respondent Pelayo filed a Complaint against Petitioner Sulpicio Lines charging it with
constructive dismissal on the ground that she was being coerced to admit complicity with Tan
and Sobiaco as to the anomalies discovered in its Davao City branch.

Decision of the Court


NO. Citing the case of Philippine Airlines vs. National Labor Relations Commission, it upheld
the validity of management prerogative in the discipline of employees. In general, management
has the prerogative to discipline its employees and to impose appropriate penalties on erring
workers pursuant to company rules and regulations. Also, not every inconvenience, disruption,
difficulty, or disadvantage that an employee must endure sustains a finding of constructive
dismissal (Manalo vs. Ateneo de Naga University).

Instruction Learned
An employer who conducts investigations following the discovery of misdeeds by its employees
is not being abusive when it seeks information from an employee involved in the workflow
which occasioned the misdeed.

Ratio
Employees cannot tie employers’ hands, incapacitating them, and preemptively defeating
investigations with laments of how the travails of their involvement in such investigations
translates to their employers’ fabrication of an inhospitable employment atmosphere so that an
employee is left with no recourse but to resign. Moreover, it is cited in the case of Rural Bank of
Cantilan, Inc. vs Julve that while the law imposes many obligations upon the employer, it also
protects the employer’s right to expect from its employees not only good performance, adequate
work and diligence, but also good conduct and loyalty. In fact, the Labor Code does not excuse
employees from complying with valid company policies and reasonable regulations for their
governance and guidance.

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