
SUPREME COURT - THIRD DIVISION
[ G.R. No. 251736, April 02, 2025 ]
PAOLO LANDAYAN ARAGONES, PETITIONER, VS. ALLTECH BIOTECHNOLOGY CORPORATION, OCTAVIO ECKHARDT, AND MATTHEW SMITH, RESPONDENTS.
Case Summary: Perfection of Employment Contract & Illegal Dismissal
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- This case clarifies the distinction between the perfection of an employment contract and the commencement of an employer-employee relationship. The Supreme Court ruled that an employment relationship was established the moment the employee accepted the job offer, even though the start date was set for a future time. The company's subsequent withdrawal of the offer before the start date, based on an unsubstantiated claim of redundancy, constituted illegal dismissal.
- The Job Offer: On April 1, 2016, Alltech offered Paolo Aragones the position of Swine Technical Manager – Pacific, with a specified commencement date of July 1, 2016.
- Acceptance and Resignation: Aragones accepted and signed the offer on April 18, 2016. Based on this, he resigned from his previous job.
- Withdrawal of Offer: On June 10, 2016, before his start date, Alltech informed Aragones that the position had been abolished due to a global restructuring program, effectively withdrawing the job offer.
- Labor Complaint: Aragones filed a complaint for non-payment of wages and damages, which was later treated as a case for illegal dismissal.
- Labor Arbiter (LA) Ruling: The LA ruled that an employer-employee relationship was perfected upon acceptance of the offer and found Aragones was illegally dismissed.
- NLRC Ruling: The NLRC reversed, stating no employment relationship existed because the employment had not yet commenced on the specified start date.
- Court of Appeals (CA) Ruling: The CA affirmed the NLRC, holding that the employment was conditioned on the availability of the position, which was abolished before the start date.
- Did an employer-employee relationship exist between Aragones and Alltech upon his acceptance of the job offer on April 18, 2016?
- If so, was Aragones illegally dismissed?
The Supreme Court GRANTED the petition, finding that Aragones was illegally dismissed.
- Employment Relationship Existed: The Court ruled that an employment contract was perfected on April 18, 2016, when Aragones accepted the offer. The July 1, 2016 start date was a *suspensive period* (a day certain), not a *suspensive condition* (an uncertain event). The period only deferred the demandability of the parties' obligations, it did not prevent the existence of the employment relationship itself.
- Illegal Dismissal Due to Unproven Redundancy: Alltech's claim of redundancy was not supported by substantial evidence. A single, vague affidavit from a company officer was insufficient to prove that the restructuring program was valid and that Aragones's position was genuinely superfluous.
- Entitlement to Relief: Aragones was awarded backwages and separation pay (in lieu of reinstatement) computed from his intended start date of July 1, 2016, until the finality of the decision, plus attorney's fees.
- Perfection of Employment Contract: An employment contract is perfected upon the meeting of the minds (offer and absolute acceptance), establishing an employer-employee relationship at that moment.
- Suspensive Period vs. Suspensive Condition: A *period* (a day certain, like a start date) only affects the demandability of an obligation, not its existence. A *condition* (an uncertain event) affects the very existence of the obligation.
- Proof of Redundancy: An employer must produce adequate and substantial proof to justify dismissal on the ground of redundancy. A mere declaration or a vague, uncorroborated affidavit is insufficient.