Aragones v. Alltech Biotechnology Corporation (2025)

Aragones v. Alltech Biotechnology Corporation, G.R. No. 251736, April 2, 2025, Per Caguioa, J.:

⦁ 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 Letter8 dated April 1, 2016. The Offer Letter outlines the terms and conditions for the position, including the following provisions:

Probation Period: 6 months from commencement date

Commencement date: 1st July 2016

Employment Contract: You are required to sign an employment contract with Alltech Biotechnology [Corporation] on your first day of work.

⦁ 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.

⦁ 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. “Consent” is manifested by the meeting of the offer and the acceptance upon the thing and the cause which are to constitute the contract. For consent to be valid, the “offer” must be certain, and the “acceptance” must be absolute. 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 [essential requisites of a contract: consent, object, and cause of the obligation], the Court finds that an employment contract between Aragones and Alltech 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, Alltech cannot claim that it validly withdrew its job offer in view of the general rule that an offer, once accepted, cannot be withdrawn.

See: Original Decision