Published 30 May 2025, The Daily Tribune
In a landmark decision, the Philippine Supreme Court clarified that a signed job offer letter can establish an employer-employee relationship, even before the employee commences work. This ruling has significant implications for both employers and employees, emphasizing the importance of understanding the legal weight of job offers and the necessity of adhering to due process in employment terminations.
The case in question involved Paolo Landayan Aragones and Alltech Biotechnology Corporation. On April 1, 2016, Alltech offered Aragones the position of Swine Technical Manager – Pacific, with a commencement date of July 1, 2016. Aragones accepted the offer by signing the job offer letter on April 18, 2016, and subsequently resigned from his previous employment. However, before his start date, Alltech rescinded the offer, citing a global restructuring that rendered the position redundant.
Aragones filed a complaint for illegal dismissal. The Labor Arbiter ruled in his favor, recognizing the existence of an employer-employee relationship based on the signed job offer and finding the dismissal illegal due to lack of substantive and procedural due process. However, the National Labor Relations Commission (NLRC) and the Court of Appeals (CA) reversed this decision, holding that no employment relationship existed as Aragones had not commenced work.
Upon review, the Supreme Court reinstated the Labor Arbiter’s decision. The Court emphasized that a contract is perfected upon mutual consent, a definite object, and a lawful cause. In this case, the signed job offer constituted a perfected contract, establishing an employer-employee relationship. The commencement date was deemed a suspensive period, indicating when obligations become demandable, not when the contract takes effect.
Furthermore, the Court held that Alltech’s unilateral withdrawal of the job offer, under the guise of redundancy, was invalid. The company failed to provide sufficient evidence of a bona fide redundancy program, such as a new staffing pattern or feasibility studies. A mere affidavit from a company officer was deemed inadequate to substantiate the claim of redundancy.
This ruling underscores the legal significance of job offer letters. Employers must recognize that once an offer is accepted, it creates binding obligations. Any termination, even before the employee starts work, must comply with labor laws, including valid grounds and due process. Employees, on the other hand, should understand that accepting a job offer can establish an employment relationship, granting them certain rights and protections under the law.
In conclusion, the Supreme Court’s decision serves as a cautionary tale for employers to exercise diligence and fairness in their hiring and termination practices. It also empowers employees to be aware of their rights from the moment they accept a job offer. Both parties must navigate the employment process with a clear understanding of their legal obligations and entitlements.
For more of Dean Nilo Divina’s legal tidbits, please visit www.divinalaw.com. For comments and questions, please send an email to cad@divinalaw.com.
