PHARMACIA v. RICARDO P.

ALBAYDA
GR No. 172724, 2010-08-23

FACTS
Respondent Ricardo P. Albayda, Jr. was an employee of Upjohn, Inc. until a merger
between Pharmacia and Upjohn took place in 1996. Post-merger, Albayda was designated as
District Sales Manager for District XI in Western Visayas. Later, he was reassigned to District
XII in Northern Mindanao, specifically Cagayan de Oro City. Albayda contested this transfer
through letters to the company's Vice-President for Sales and Marketing, citing his unfamiliarity
with the new territory, disruption to his family life, and potential dismissal from employment.

Despite warnings and notices from the company, Albayda did not report for work in the
new assignment, leading to his termination.

ISSUE
Whether the Court of Appeals (Cebu City) can reverse or set aside the factual and legal findings
of the NLRC based on substantial evidence without palpable error or if the findings of the Labor
Arbiter contradict those of the NLRC.

RULING
The court recognized the management prerogative to transfer employees as long as it
does not involve demotion, discrimination, bad faith, or punishment without sufficient cause. It
also considered whether the transfer was unreasonable, inconvenient, or prejudicial to the
employee.

In this case, the court found the transfer valid as a legitimate exercise of management
prerogative aimed at maximizing business opportunities and developing personnel. It was noted
that Albayda's expertise was required to improve business performance in Cagayan de Oro City.
The court ruled that the transfer was not a demotion, as Albayda would still serve as a District
Sales Manager, and there was no indication of reduced emoluments. Additionally, the company
offered relocation benefits and allowance per their Benefits Manual.