Scribd
Upload
61 views1 page

Abbot Laboratories V Alcaraz

This case discusses the standards for regularizing a probationary employee. The Supreme Court found that the Court of Appeals erred in deferring to the National Labor Relations Commission's decision, as the NLRC arbitrarily disregarded circumstances showing the employee was informed of performance standards. While the NLRC's decisions are normally final, the Supreme Court can consider other legal questions to determine if labor law principles were correctly applied. The Court ultimately ruled that the circumstances indicated the employee was aware of the standards, so the NLRC wrongly treated her as a regular employee eligible for regularization.

Uploaded by

Mharey Almacha
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
61 views1 page

Abbot Laboratories V Alcaraz

This case discusses the standards for regularizing a probationary employee. The Supreme Court found that the Court of Appeals erred in deferring to the National Labor Relations Commission's decision, as the NLRC arbitrarily disregarded circumstances showing the employee was informed of performance standards. While the NLRC's decisions are normally final, the Supreme Court can consider other legal questions to determine if labor law principles were correctly applied. The Court ultimately ruled that the circumstances indicated the employee was aware of the standards, so the NLRC wrongly treated her as a regular employee eligible for regularization.

Uploaded by

Mharey Almacha
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 1

Abbot Laboratories v Alcaraz

G.R. No. 192571 Resolution dated April 22, 2014

Doctrine: It is not the probationary employee’s job description but the


adequate performance of his duties and responsibilities which constitutes
the inherent and implied standard for regularization.

FACTS: Respondent Alcaraz was employed in petitioner company as a


Regulatory Affairs Manager on a probationary status for six months.
Teresita Bernardo sent her copies of Abbot’s organizational structure and
her job description through e-mail. She was then underwent to a pre-
employment orientation informing her that she had to implement Abbot’s
Code of Conduct. She was also required to undergo a training program.
Maria Yabut-Misa, also petitioner, explained to her the procedure for
evaluating the performance of probationary employees and notified her
that Abbott had only one evaluation system for all of its employees.
Alcaraz was terminated because she did not manage her time effectively
and was not able to obtain the knowledge and ability to make sound
judgments on case processing and article review which were necessary
for the proper performance of her duties, among others. Alcaraz contends
that she was not informed on the standards of regularization. Further, she
posits that one’s job description cannot by and of itself treated as a
standard for regularization as a standard denotes a measure of quantity or
quality.

Issue: Whether the Supreme Court should only determine whether or not the CA properly determined
that the NLRC committed a grave abuse of discretion.

Ruling: No, the assertion does not justify the reconsideration of the assailed decision. A careful perusal of
the questioned Decision will reveal that the Court actually resolved the controversy under the above-
stated framework of analysis. Essentially, the Court found the CA to have committed an error in holding
that no grave abuse of discretion can be ascribed to the NLRC since the latter arbitrarily disregarded the
legal implication of the attendant circumstances in this case which should have simply resulted in the
finding that Alcaraz was apprised of the performance standards for her regularization and hence, was
properly a probationary employee. It bears exposition that while NLRC decisions are, by their nature,
final and executory and, hence, not subject to appellate review, the Court is not precluded from
considering other questions of law aside from the CA’s finding on the NLRC’s grave abuse of discretion.
While the focal point of analysis revolves on this issue, the Court may deal with ancillary issues – such as,
in this case, the question of how a probationary employee is deemed to have been informed of the
standards of his regularization – if only to determine if the concepts and principles of labor law were
correctly applied or misapplied by the NLRC in its decision. In other words, the Court’s analysis of the
NLRC’s interpretation of the environmental principles and concepts of labor law is not completely
prohibited in – as it is complementary to – a Rule 45 review of labor cases.

Consequently, since the CA found that the NLRC did not commit grave abuse of discretion and denied
the certiorari petition before it, the reversal of its ruling was thus in order.

You might also like