Case Title: EAST CAM TECH CORPORATION v. BAMBIE T. FERNANDEZ, et. al., G.R. No.
222289, June 08, 2020 (REYES, J. JR., J.)
Instruction learned:
1. Whether failure to meet the quota constitutes gross negligence.
In Aliling, the Court recognized management prerogative to fix a quota for its
employees, and failure to meet the quota constitutes gross negligence, provided that
such quota was imposed in good faith. In Aliling, the Court held:
In fine, an employee's failure to meet sales or work quotas falls under the concept of
gross inefficiency, which in turn is analogous to gross neglect of duty that is a just cause
for dismissal under Article 282 of the Code. However, in order for the quota imposed to
be considered a valid productivity standard and thereby validate a dismissal,
management's prerogative of fixing the quota must be exercised in good faith for the
advancement of its interest. The duty to prove good faith, however, rests with WWWEC
as part of its burden to show that the dismissal was for a just cause. WWWEC must
show that such quota was imposed in good faith. This WWWEC failed to do, perceptibly
because it could not. The fact of the matter is that the alleged imposition of the quota
was a desperate attempt to lend a semblance of validity to Aliling's illegal dismissal. xx x
2. Whether the petitioner has acted in good faith.
Here, East Cam, as the employer, has the right to impose production quotas in its
production line based on its TMS for job orders one and two. However, East Cam failed
to prove that it acted in good faith when it did not adduce any evidence that its TMS
were attainable based on the quantity it wanted to produce for a given time, quality of
the product to be produced, the machines they have, and the skill sets of their
employees. Further, East Cam failed to rebut the respondents' allegations that: (1) the
machines assigned to them were old and worn out, (2) they were stationed at a place far
from the sample room where all the special machines are located, and (3) they were the
only ones required to meet a production quota and to submit hourly reports.
The Court only upholds management prerogative as long as it is exercised in good faith
for the advancement of the employer's interest and not for the purpose of defeating or
circumventing the employees' rights under special laws and valid agreements.