Photo from Unsplash | Amina Atar
The following post does not create a lawyer-client relationship between Alburo Alburo and Associates Law Offices (or any of its lawyers) and the reader. It is still best for you to engage the services of a lawyer or you may directly contact and consult Alburo Alburo and Associates Law Offices to address your specific legal concerns, if there is any.
Also, the matters contained in the following were written in accordance with the law, rules, and jurisprudence prevailing at the time of writing and posting, and do not include any future developments on the subject matter under discussion.
AT A GLANCE:
An employment contract, like any other contract, is perfected at the moment the parties come to agree upon its terms and conditions, and thereafter, concur in the essential elements thereof.
On April 1, 2016, petitioner Paolo Landayan Aragones (Aragones) was offered the position Swine Technical Manager – Pacific (STMP) by respondent Alltech Biotechnology Corporation (Alltech). On April 18, 2016, Aragones signed the Offer Letter dated April 1, 2016.
The Offer Letter outlines the terms and conditions for the position, including the commencement date of his employment which is July 1, 2016.
On April 25, 2016, Aragones resigned from and severed his employment with Cargill Philippines, Inc. (Cargill). In the meantime, Alltech’ s Head Office allegedly implemented a global restructuring program in May 2016. As a result, the position of Swine Technical Manager – Pacific (STMP), along with other similar positions across the Alltech group, allegedly became redundant and was abolished. Alltech informed Aragones of this development through a letter dated June 10, 2016, and offered him PHP 140,000.00, an amount equivalent to one-month salary, as a gesture of goodwill.
Aragones did not respond to Alltech. Instead, he filed a complaint for non-payment of wages, moral and exemplary damages, attorney’s fees, other causes of action, interest, expenses, money claims and backwages.
The Labor Arbiter found that Aragones was illegally dismissed. According to the LA, an employer-employee relationship was established when Aragones accepted Alltech’s job offer. On appeal, the reversed the LA decision and dismissed the complaint for lack of jurisdiction. The CA denied Aragones’ petition for certiorari.
Issue: Whether an employer-employee relationship existed between Aragones and Alltech.
The Supreme Court’s Decision
A contract is perfected upon the concurrence of the following requisites: (1) the consent of the contracting parties; (2) an object certain, which is the subject matter of the contract; and (3) the cause of the obligation. A contract is deemed perfected from the time the acceptance is made known to the offeror. Without the offeror’s knowledge of the acceptance, there is no meeting of the minds of the parties, and thus, no real concurrence of offer and acceptance.
An employment contract, like any other contract, is perfected at the moment the parties come to agree upon its terms and conditions, and thereafter, concur in the essential elements thereof.
Based on these requirements, the Court finds that an employment contract between Aragones and All tech was perfected on April 18, 2016. This conclusion is supported by the following undisputed facts: (a) Alltech made an offer that is certain through the Job Offer; (b) Aragones unequivocally accepted this offer by affixing his signature thereon on April 18, 2016; and (c) he informed Alltech of his acceptance by sending a copy of the signed Job Offer to respondent Octavio Eckhardt (Eckhardt) via e-mail on the same day.
Thus, All tech cannot claim that it validly withdrew its job offer in view of the general rule that an offer, once accepted, cannot be withdrawn.
The contract between Aragones and Alltech is subject to a term or a period-a specific date agreed upon by the parties, July 1, 2016. The Supreme Court found that the commencement date agreed upon by the parties is a suspensive period that merely deferred the demandability of their respective obligations as employer and employee-namely, the employee’s obligation to render services and the employer’s obligation to pay wages. It did not affect the existence or birth of those obligations.
In other words, while the employer-employee relationship was already established when the contract was entered into on April 18, 2016, the demandability of their respective obligations as employer and employee was deferred until July 1, 2016.
Source:
Paolo Landayan Aragones Vs. Alltech Biotechnology Corporation, Octavio Eckhardt, and Matthew Smith
G.R. No. 251736 | April 2, 2025
SC: Signed Job Offer Creates Employer-Employee Relationship; Redundancy Requires Proof
Click here to subscribe to our newsletter
Alburo Alburo and Associates Law Offices specializes in business law and labor law consulting. For inquiries regarding legal services, you may reach us at info@alburolaw.com, or dial us at (02)7745-4391/ 0917-5772207/ 09778050020.
All rights reserved.