Title
Abapo vs. Court of Appeals
Case
G.R. No. 142405
Decision Date
Sep 30, 2004
Former SMC employees challenged their 1992 termination under a modernization program, alleging illegal layoff. Courts upheld the validity of termination, citing compliance with labor laws, binding quitclaims, and procedural lapses in their petition.
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Case Digest (G.R. No. 142405)

Facts:

Background of the Case:

  • The 120 petitioners were former employees of San Miguel Corporation (SMC), assigned to the Mandaue Brewery Plant.
  • In 1991, SMC conducted a viability study and implemented a modernization program, introducing high-speed machines in bottling lines 6 and 7. This rendered several employee functions redundant, leading to the cessation of operations in lines 1, 2, 3, 4, and 5.

Termination and Compensation:

  • On February 13, 1992, SMC notified the Department of Labor and Employment (DOLE) of the termination of the employees listed.
  • On February 7, 1992, and September 28, 1992, SMC informed the affected employees of their separation, offering:
    • 175% of their monthly salary for every year of service as separation pay.
    • 3-year free hospitalization coverage.
    • Free training and consultation for livelihood programs.
    • Assistance in local and overseas job placements.
  • The employees accepted the compensation and executed quitclaims before DOLE officers.

Labor Complaints:

  • Two years later, the employees filed complaints with the Labor Arbiter (NLRC Cases Nos. RAB VII-11-1175-95 and RAB VII-01-0096-96), alleging that SMC’s modernization program was a pretext for illegal mass layoff.
  • They sought:
    • Declaration of illegal termination.
    • Payment of backwages, separation pay, and other benefits.

Labor Arbiter and NLRC Decisions:

  • On November 25, 1996, the Labor Arbiter dismissed the complaints.
  • On appeal (NLRC Case No. V-0099-97), the NLRC affirmed the dismissal, ruling against the employees.

Court of Appeals Proceedings:

  • The petitioners filed a special civil action for certiorari with the Court of Appeals, which was dismissed due to:
    1. Failure to attach a certified true copy of the NLRC Resolution.
    2. Filing the petition seven (7) days beyond the reglementary period.
  • The motion for reconsideration was also denied.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Technical Compliance with Rules: The failure to attach a certified true copy of the NLRC Resolution and the late filing of the petition are sufficient grounds for dismissal under Rule 46, Section 3 of the 1997 Rules of Civil Procedure.
  2. Validity of Termination: The installation of labor-saving devices as part of SMC’s modernization program is a valid ground for termination under the Labor Code.
  3. Binding Effect of Quitclaims: The quitclaims executed by the employees, after receiving separation pay and other benefits, are valid and enforceable as reasonable settlements.
  4. Jurisprudential Support: The Court cited Agustilo vs. Court of Appeals, which upheld the validity of similar terminations by SMC under its modernization program.

Conclusion:

The Supreme Court ruled that the Court of Appeals did not commit grave abuse of discretion in dismissing the petition. The termination of the petitioners’ employment was valid, and the quitclaims they signed were binding. The petition was denied, and the Court of Appeals’ Resolutions were affirmed in toto.


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