Altarejos, Seanne Angelo M.

BASS 2-B CASE DIGEST | HURAPE

Blue Eagle Management, Inc. v Jocelyn Naval.

G.R. No. 192488 | April 19, 2016
Justice Presbitero J. Velasco Jr.

Facts:
Jocelyn Naval (Naval) was employed as a sales agent by Blue Eagle Management, Inc. (Blue
Eagle). After five months of employment, Naval was terminated for alleged failure to meet her
sales quota.

Naval filed a complaint for illegal dismissal and non-payment of commissions against Blue
Eagle. The Labor Arbiter found Blue Eagle guilty of illegal dismissal and ordered the company
to reinstate Naval and pay her back wages and commissions. On appeal, the National Labor
Relations Commission (NLRC) affirmed the Labor Arbiter’s decision.

Blue Eagle filed a petition for certiorari before the Court of Appeals (CA) to challenge the
NLRC’s decision. The CA denied the petition and upheld the NLRC’s decision. Hence, Blue
Eagle filed a petition for review on certiorari before the Supreme Court.

Issue:
Whether or not Naval was illegally dismissed

Ruling:
Meritorious. No, Naval was not legally dismissed by Blue Eagle Management, Inc. The company
failed to prove that Naval was terminated for a valid reason, did not provide her with due process
before the termination, and relied on arbitrary and unfair standards for evaluating her
performance. Therefore, the decision of the National Labor Relations Commission finding Blue
Eagle guilty of illegal dismissal and ordering the company to reinstate Naval and pay her back
wages and commissions is affirmed.

Doctrine:
Employers are bound to prove that an employee was terminated for just cause and failure to do
so would result in the finding of illegal dismissal and the awarding of damages.

Conclusion/ Point-of-view:
The case of Blue Eagle Management, Inc. v. Jocelyn Naval highlights the importance of due
process in employee termination and the burden of proof on employers to justify a dismissal
based on a just cause. It also emphasizes the need for employers to provide clear and definite
standards for evaluating an employee's performance, such as a specific sales quota, and to give
employees ample opportunity to improve their performance before resorting to termination. The
decision also underscores the rights of employees to be protected against illegal dismissal and to
receive just compensation for any damages incurred.
Altarejos, Seanne Angelo M. BASS 2-B CASE DIGEST | HURAPE

Christine Joy Capin-Cadiz v. Brent Hospital and Colleges

G.R. No. 187417 | February 24, 2016
Associate Justice Estela M. Perlas-Bernabe

Facts:
Christine Joy Capin-Cadiz was the Human Resource Officer of respondent Brent Hospital and
Colleges, Inc. (Brent) at the time of her indefinite suspension from employment in 2006. The
cause of suspension was Cadiz's Unprofessionalism and Unethical Behavior Resulting to Unwed
Pregnancy. It appears that Cadiz became pregnant out of wedlock, and Brent imposed the
suspension until such time that she marries her boyfriend in accordance with law.

Cadiz then filed with the Labor Arbiter (LA) a complaint for Unfair Labor Practice, Constructive
Dismissal, Non-Payment of Wages and Damages with prayer for Reinstatement.
Issues:
Whether or not Cadiz was illegally dismissed and entitled to reinstatement and backwages.

Ruling:
Meritorious. Yes, Brent Hospital and Colleges is liable for damages incurred by Christine Joy
Capin-Cadiz due to their failure to provide timely and appropriate medical treatment. The
hospital was negligent in administering an incorrect treatment plan for Capin-Cadiz without
proper investigation and assessment of her condition, resulting in serious complications and
damages. Therefore, the decision of the Regional Trial Court awarding Capin-Cadiz damages for
actual, moral, and exemplary damages, as well as attorney's fees, is affirmed.

Doctrine:
The case of Christine Joy Capin-Cadiz v. Brent Hospital and Colleges reiterates the importance
of procedural due process in employment termination cases. Employers are required to give
employees notice and an opportunity to be heard before dismissal, especially when there are
serious allegations of misconduct involved. The case also highlights the need for employers to
have sufficient evidence to justify the dismissal of an employee, as unsubstantiated allegations
could lead to a finding of illegal dismissal.

Conclusion/ Point-of-view:
The case of Christine Joy Capin-Cadiz v. Brent Hospital and Colleges, Inc. highlights the
importance of upholding the rights of employees, particularly the right to security of tenure.

The Court's decision to order Cadiz's reinstatement and award back wages and other benefits
shows the significant consequences for employers who do not follow the proper procedures in
dismissing employees. As such, this case underscores the need for employers to act in good faith
and with due diligence in handling employment matters to avoid legal disputes and protect their
employees' rights.