Julies Bakeshop vs Arnaiz

Facts:

 Petitioner hired respondents as chief bakers in his three franchise branches of Julie’s Bakeshop in Sibalom and San Jose, Antique. On Jan. 26, 2000, respondents filed separate complaints against petitioners for labor standard benefits and attorney’s fees.Subsequently, in a memorandum dated Feb. 16, 2000, Reyes reassigned respondents as utility/security personnel tasked to clean the outside vicinity of his bakeshops and to maintain peace and order in the area.Petitioners insist that the transfer or reassignment of respondents is a valid exercise of management prerogative for it does not involve any diminution in pay and privileges. It was a measure of self-preservation and was prompted by a desire to protect the health of the buying public should respondents sabotage the business pending resolution of their cases. 

Issue: 

Whether there is demotion.

Held: 

No. The transfer of respondents amounted to a demotion. Although there was no diminution in pay, there was undoubtedly a demotion in titular rank. One cannot deny the disparity between the duties and functions of a chief baker with that of a utility/security personnel tasked to clean and manage the orderliness of the outside premises of the bakeshop. Respondents were even prohibited from entering the bakeshop. The change in the nature of their work undeniably resulted to a demeaning and humiliating work condition.The act attributed against Tolores does not even convince us as he was merely a suspected culprit in the alleged sabotage, for which no investigation took place to establish his guilt or culpability.Besides, Reyes still retained Tolores as an employee and chief baker when he could have dismissed him for cause if the allegations were indeed found true. The transfer was an act of retaliation on the part of petitioners due to the former’s filing of complaints against them, and thus, was clearly made in bad faith .In fact, petitioner Reyes even admitted that he caused the reassignments due to the pending complaints filed against him.