Sameer Overseas Placement Agency Inc. v.

Cabiles, GR No 170139

FACTS:
Respondent Joy Cabiles was hired by Wacoal Taiwan, Inc., through petitioner agency Sameer Overseas Placement
Agency as a cutter. Subsequently, Cabiles was informed that her services are already terminated and that she must
report to their head office for her immediate repatriation. Because of this, Cabiles filed a complaint for illegal
dismissal against Sameer and Wacoal. The Labor Arbiter ruled in favor of Sameer and held that there was no illegal
dismissal that took place because the termination of the services of Cabiles was for a just cause. It gave credence to
the contention of Sameer that Cabiles was terminated from service because of her inefficiency. On appeal, the NLRC
ruled in favor of Cabiles and held that she is illegally dismissed. The Court of Appeals affirmed the ruling of NLRC.
Hence, the current petition.

Sameer reiterates that there was just cause for termination because there was a finding of Wacoal that respondent
was inefficient in her work. Therefore, it claims that respondent’s dismissal was valid.

ISSUE:
Whether or not respondent Cabiles was illegally dismissed.

RULING:
Yes. The Supreme Court affirmed the decision of the Court of Appeals and ruled that the respondent was illegally
dismissed. Sameer Overseas Placement Agency failed to show that there was just cause for causing Joy’s dismissal.
The employer, Wacoal, also failed to accord her due process of law. Indeed, employers have the prerogative to
impose productivity and quality standards at work. They may also impose reasonable rules to ensure that the
employees comply with these standards. Failure to comply may be a just cause for their dismissal. Certainly,
employers cannot be compelled to retain the services of an employee who is guilty of acts that are inimical to the
interest of the employer. While the law acknowledges the plight and vulnerability of workers, it does not “authorize the
oppression or self-destruction of the employer.” Management prerogative is recognized in law and in our
jurisprudence.

Sameer’s allegation that respondent was inefficient in her work and negligent in her duties may, therefore, constitute
a just cause for termination under Article 282(b), but only if petitioner was able to prove it.

Sameer failed to comply with the twin notices and hearing requirements. Respondent started working on June 26,
1997. She was told that she was terminated on July 14, 1997 effective on the same day and barely a month from her
first workday. She was also repatriated on the same day that she was informed of her termination. The abruptness of
the termination negated any finding that she was properly notified and given the opportunity to be heard. Her
constitutional right to due process of law was violated.