Abbott Laboratories v. Alcaraz (2013)

Abbott Laboratories v. Alcaraz, En Banc, G.R. No. 192571, July 23, 2013, Perlas-Bernabe., J.:

1. Background

• On June 27, 2004, [petitioners-employers] Abbott Laboratories, Philippines (Abbott) caused the publication in a major broadsheet newspaper of its need for a Medical and Regulatory Affairs Manager (Regulatory Affairs Manager) who would: (a) be responsible for drug safety surveillance operations, staffing, and budget; (b) lead the development and implementation of standard operating procedures/policies for drug safety surveillance and vigilance; and (c) act as the primary interface with internal and external customers regarding safety operations and queries.4 Alcaraz - who was then a Regulatory Affairs and Information Manager at Aventis Pasteur Philippines, Incorporated (another pharmaceutical company like Abbott) – showed interest and submitted her application on October 4, 2004.

• On December 7, 2004, Abbott formally offered [the employee] Alcaraz the abovementioned position which was an item under the company’s Hospira Affiliate Local Surveillance Unit (ALSU) department. In Abbott’s offer sheet. it was stated that Alcaraz was to be employed on a probationary basis. Later that day, she accepted the said offer and received an electronic mail (e-mail) from Abbott’s Recruitment Officer, [petitioners-employers] Teresita C. Bernardo (Bernardo), confirming the same. Attached to Bernardo’s e-mail were Abbott’s organizational chart and a job description of Alcaraz’s...

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