REPEATED FAILURE TO REACH MONTHLY SALES QUOTA CONSTITUTES GROSS INEFFICIENCY

Puncia vs. Toyota Shaw
G.R. No. 214399 June 28, 2016

Gross inefficiency

Puncia’s repeated failure to perform his duties -i.e., reaching his monthly sales quota -for such a period of time falls under the concept of gross inefficiency. In this regard, case law instructs that “gross inefficiency” is analogous to “gross neglect of duty,” a just cause of dismissal under Article 297 of the Labor Code, for both involve specific acts of omission on the part of the employee resulting in damage to the employer or to his business.

Employer’s right to impose productivity standards

In Aliling vs. Feliciano, the Court held that an employer is entitled to impose productivity standards for its employees, and the latter’s non-compliance therewith can lead to his termination from work (Such inefficiency is understood to mean failure to attain work goals or work quotas, either by failing to complete the same within the allotted reasonable period, or by producing unsatisfactory results.)

Dismissing employee on the ground different from that being charged

While Toyota afforded Puncia the opportunity to refute the charge of gross inefficiency against him, the latter was completely deprived of the same when he was dismissed for gross insubordination – a completely different ground from what was stated in the Notice to Explain. As such, Puncia’s right to procedural due process was violated. Hence, considering that Toyota had dismissed Puncia for a just cause, albeit failed to comply with the proper procedural requirements, the former should pay the latter nominal damages in the amount of P30,000.00 in accordance with recent jurisprudence.