Job offer acceptance equals employment

Job offer acceptance equals employment | Daily Tribune

A job offer, standing alone, does not always amount to an employment contract. Yet once the parties come to an agreement on the essential terms and conditions, the contract is deemed perfected — even if the actual work has not yet commenced.

This principle, while not new, was emphatically reaffirmed by the Supreme Court in the recent case of Aragones v. Alltech Biotechnology Corporation, et al., G.R. 251736, 2 April 2025.

In that case, the employee accepted a job offer by affixing his signature on the offer letter and sending it back to the employer. The letter contained a specific commencement date — 1 July 2016 — and required that a formal employment contract be executed on the first working day.

Less than a month later, however, the employer abruptly abolished the very position it had offered, invoking redundancy. The applicant, who had already resigned from his previous employment in anticipation of his new post, was left unemployed. He thus filed a complaint for illegal dismissal.

The Labor Arbiter ruled in his favor, but the National Labor Relations Commission (NLRC) overturned the ruling, reasoning that no employer-employee relationship yet existed. The NLRC anchored its decision on the fact that the designated start date had not yet arrived and that no definitive employment contract had been signed. The Court of Appeals affirmed.

The Supreme Court, however, took a different view. It annulled the appellate court’s decision and categorically held that the employment contract had already been perfected when the applicant accepted the job offer by signing the offer letter.

The stipulation that he would commence work at a stipulated date did not negate the existence of the employment relationship

The Court clarified that the date merely fixed the period when the obligations of the parties would become demandable.

Contracts with a period are still valid and binding from the moment of perfection; only the enforceability of the obligations is deferred.

This clarification is consistent with the Court’s earlier pronouncement in Gesolgon, et al. v. Cyberzone Ph., Inc., et al., G.R. 210741, 14 October 2020, where it reiterated that once parties agree on the essential elements of employment — consent, object, and cause — the contract is already perfected.

No particular form is required to prove the existence of an employer-employee relationship. What matters is the meeting of the minds.

The Court ruled that this was grossly insufficient. Redundancy, to be valid, must be supported by substantial evidence — clear proof that the restructuring is necessary, that specific positions are indeed superfluous, and that objective criteria were used in identifying which positions to abolish. Without such proof, claims of redundancy remain self-serving and cannot justify dismissal.

Consequently, the Court declared the employee to have been illegally dismissed. Since reinstatement was no longer sought, the award of separation pay in lieu of reinstatement was proper. Backwages, on the other hand, were to be computed from the date when the employee could already demand to be given work and paid — until the finality of the Court’s decision.

This computation is consistent with the Court’s more recent doctrine in C.P. Reyes Hospital v. Barbosa, G.R. 228357, 26 April 2024, which abandoned the earlier ruling in Robinsons Galleria, et al. v. Ranchez, G.R. 177937, 19 January 2011.

The lesson here is clear. For employers, extending an offer of employment is not a casual step. Once accepted, the law deems an employment relationship established, and obligations arise. For employees, the decision assures protection even before physically reporting for work, so long as the offer has been duly accepted.

Ultimately, the Court’s ruling fortifies the constitutional policy of affording full protection to labor. It sends a strong message that employment rights cannot be evaded by technicalities or deferred indefinitely by contractual stipulations. The moment consent is given and acceptance is communicated, the bond of employment exists — with all its attendant consequences.