Case Digest (G.R. No. 229746)
Facts:
Abbott Laboratories (Philippines), Inc. and Stephane Langevin, petitioners, filed a Petition for Review on Certiorari under Rule 45 (G.R. No. 229746, October 11, 2017, Supreme Court Third Division), with Justice Velasco Jr., J., writing for the Court. The case concerns the validity of a corporate redundancy program and the legality of the dismissal of three sales managers: Manuel F. Torralba, Roselle P. Almazar, and Redel Ulysses M. Navarro.Almazar (hired June 1, 1992), Torralba (hired July 4, 1988) and Navarro (hired June 1, 1993) occupied supervisory posts in Abbott’s PediaSure Division as National and Regional Sales Managers and received substantial monthly compensation. In November 2012 Abbott decided to merge the PediaSure Division with the Medical Nutrition Division after conducting a study entitled “Specialty Nutrition Group Sales Force Restructure Philippines,” and declared certain positions redundant. Abbott notified DOLE and the employees on February 18, 2013, that terminations would be effective March 22, 2013, and offered the affected employees newly created District Sales Manager posts with lower job rates and different duties; the employees rejected these offers.
On or about May 10, 2013 the respondents signed Deeds of Waiver, Release and Quitclaim after receiving separation pay (Torralba PhP4,111,700.25 plus last pay; Navarro PhP2,612,783.40 plus last pay; Almazar PhP3,116,555.82). On September 20, 2013 the respondents filed complaints for illegal dismissal, underpayment of separation pay and discrimination, moral and exemplary damages, and attorney’s fees, alleging Abbott failed to use fair and reasonable selection criteria (status, efficiency, seniority or other evaluative measures) and that the Deeds were vitiated by fraud or mistake.
Before the Labor Arbiter, Abbott defended that redundancy was an authorized cause, that the Study justified integration and retention decisions, that separation pay paid exceeded statutory minima, and that the signed Deeds were voluntary. On February 4, 2014 Labor Arbiter Madjayran H. Ajan found the dismissals illegal for lack of evidence that Abbott used fair and reasonable criteria in selecting who to retain, ruled that the Deeds did not bar relief, and ordered reinstatement, full backwages, moral and exemplary damages and attorney’s fees.
Abbott appealed to the National Labor Relations Commission (NLRC). On May 20, 2014 the NLRC reversed the Labor Arbiter and dismissed the complaint, finding that the Deeds precluded the respondents’ claims; the NLRC denied reconsideration on June 23, 2014. The respondents then petitioned the Court of Appeals (CA) via certiorari.
On April 26, 2016 the CA (in CA‑G.R. SP No. 136213) granted the petition, annulled and set aside the NLRC decisions, reinstated the Labor Arbiter’s February 4, 2014 decision with the modification that backwages be computed until actual reinstatement, and ordered legal interest at 6% per annum. Abbott sought reconsideration; meanwhile Abbott furnished Return to Work Notices offering positions it characterized as equivalent. Respondents refused the improved offers in July 2016. The CA denied respondents’ motion for reconsideration on January 25, 2...(Subscriber-Only)
Issues:
- Did petitioners proved that the termination was validly effected under a redundancy program (procedural issue: burden of proof and sufficiency of the redundancy criteria)?
- Did the Deeds of Waiver, Release and Quitclaim executed by respondents bar their illegal dismissal claim (validity of quitclaims)?
- Were respondents properly denied backwages from the date of illegal dismissal up to the dates they refused reinstatement (effect of respondents’ refusal and equivalence of offered positions)?
- Were the awards of moral and exemplary damag...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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