St. Luke's Medical Center v. NLRC Digest

St. Luke's Medical Center v. NLRC

Facts:
1. The private respondent Maribel Santos worked as an X-Ray technician at the petitioner hospital (SLMC) but she does not possess  a certificate of registration as required under the newly passed Radiologic Act or RA 7431. Due to her non-compliance and her failure to pass the exams, she was separated.

2. The private respondent filed a complaint for illegal dismissal and non-payment of salaries and other monetary benefits. The Labor Arbiter ordered the petitioner to pay respondent separation pay and this was affirmed by both NLRC and the Court of Appeals, hence this petition. The petitioner contended that respondent dismissal was valid.

Issue: Whether or not an employer can validly dismiss an employee based on her inability to secure a certification as required by the Board

RULING: Yes, The petitioner is merely exercising its management prerogative and these rights are entitled respect and enforcement in the interest of fair play. There was no malice imputed upon an employer where the separation of an employee is undertaken in conformance with an existing law as in this case.

Management prerogatives include the right of the employer to determine the place or station where an employee is best qualified to serve the interests of the company on the basis of the qualifications, training and performance.