MANILA, Philippines —The Supreme Court has reiterated that an employer-employee relationship is established once a job offer is accepted, and companies cannot simply claim redundancy to justify dismissals without presenting solid proof of a valid redundancy program.

In a Decision written by Associate Justice Alfredo Benjamin S. Caguioa, the Court’s Third Division ruled that Alltech Biotechnology (Alltech) illegally dismissed Paolo Landayan Aragones after failing to prove that redundancy existed in the company.

Alltech had offered Aragones the position of Swine Technical Manager – Pacific with a monthly salary of P140,000. He accepted the offer and resigned from his previous job. But before his start date, Alltech informed him that the position was abolished due to a global restructuring and offered him P 140,000 as a goodwill payment.

Aragones filed a complaint for illegal dismissal. The Labor Arbiter ruled in his favor, but the National Labor Relations Commission (NLRC) reversed the ruling, saying no employer-employee relationship existed since Aragones had not yet started working. The Court of Appeals upheld the NLRC’s decision.

The Supreme Court, however, said the employment contract was perfected when Aragones accepted the job offer. The fact that his start date was still three months away did not mean there was no employment relationship. The Court explained that the delay only postponed Aragones’ duty to report for work and Alltech’s obligation to pay his salary. When Alltech withdrew the offer, the employer-employee relationship had already been established.

The Court also found that Alltech failed to provide adequate proof that Aragones’ dismissal was due to redundancy. Under the Labor Code, redundancy must be supported by solid evidence such as a new staffing pattern, feasibility studies, job descriptions, or management approval of restructuring.

In this case, Alltech only submitted an affidavit from its Vice President stating that the company shifted from regional to local support. The Court found the statement vague and unsupported by any documents, and it failed to explain how or why positions like Aragones’ were removed.

Since Aragones no longer wants to be reinstated, the Court ordered Alltech to pay him backwages and separation pay from his intended start date until the finality of the Decision.