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Promotion Only in Nomenclature

Posted by lexforiphilippines on September 16, 2010

When an employee’s position is converted to a higher job grade level but he is not given additional functions or responsibilities, can he be considered as “promoted” and claim conversion and promotion increase?

In SCA Hygiene Products Corporation Employees Association-FFW vs. SCA Hygiene Products Corporation (G.R. No. 182877; 9 August 2010), the Supreme Court held that of primordial consideration is not the nomenclature or title given to the employee, but the nature of his functions.  In this case, the employees concerned, although given a higher job grade level following a company-wide job evaluation, continued to occupy the same positions they were occupying before the job evaluation.  Their job titles remained the same and they were not given additional duties and responsibilities.  Like their previous job grade level, their new job grade level was also categorized as rank-and-file.  What transpired, said the High Court, was only a promotion in nomenclature, and the employees were not entitled to conversion or promotion increase.

For a digest of the case, click on Digested Cases under Tools.


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