Frequent Transfer as Indirect Dismissal
In the case at bar, the evidence show that [the employee-security guard] enjoyed a single post at the PCIBank for three (3) years. It changed after his suspension. In a span of less than three (3) months, [the employee] was assigned to at least four (4) establishments, namely, BPI Family Bank, Mercury Drugstore, Sevilla Candle Factory and Philippine Savings Bank. He suddenly found himself being tossed to different posts and relieving absent security guards. [The employee] was then left uncertain as to when and where his next assignments would be. Considering the totality of the facts of this case, the labor officials below rightly found that the frequent transfers of respondent to different posts on short periods of time were indirect ways of dismissing him.
– Philippine Industrial Security Agency Corporation v. Dapiton, G.R. No. 127241, 08 December 1999
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