Trainee Period is Computed as Part of Probationary Service
An employee was first hired as a trainee by the hotel in August 2008. His training lasted for three (3) months.
As a room boy, his performance was certainly under observation.
The Court held that his probationary employment actually started in August 2008, at the same time he started working as a trainee.
Therefore, when he was re-hired as room boy after his training period sometime in November 2008 he attained regular employment status.
(Oyster Plaza Hotel, et al. Vs. Errol O. Melivo, G.R. No. 217455, October 5, 2016 citing Holiday Inn Manila vs. NLRC)
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