Case Digest (G.R. No. L-49678)
Facts:
The case involves Allied Investigation Bureau, Inc. as the petitioner and several respondents, including Hon. Blas F. Ople, the Minister of Labor, Hon. Amado G. Inciong, the Deputy Minister of Labor, the National Labor Relations Commission, Labor Arbiter Apolonio L. Reyes, and Victoriano Velasquez, the private respondent. The events leading to this case began when Victoriano Velasquez, who commenced employment with Allied Investigation Bureau in May 1953, reached the age of sixty and applied for retirement benefits in April 1976. The company approved his application, but later offered him a retirement check of only P675.00 for two years, calculated at one-half month salary for every year of service starting from November 1, 1974, the effective date of the Labor Code, rather than from 1953 when he began working. Velasquez contested this computation, leading him to file a complaint with the Department of Labor for non-payment of retirement benefits. The Labor Arbiter ruled in f...
Case Digest (G.R. No. L-49678)
Facts:
- Employment History: Victoriano Velasquez started working for Allied Investigation Bureau, Inc. in May 1953. He retired upon reaching the age of 60 and applied for retirement benefits under the Labor Code.
- Retirement Application: Velasquez’s application for retirement was approved by the company on May 10, 1976, referencing Sections 13 and 14, Rule 1, Book VI of the Implementing Rules and Regulations of the Labor Code.
- Dispute Over Retirement Pay: The company offered Velasquez P675.00, computed at one-half month salary for every year of service from November 1, 1974 (when the Labor Code took effect). Velasquez refused, arguing that his retirement pay should be computed from May 1953, when he started working.
- Labor Complaint: Velasquez filed a complaint with the Department of Labor for non-payment of retirement benefits. The labor arbiter, National Labor Relations Commission (NLRC), and the Minister of Labor ruled in his favor, awarding him P7,762.50, computed from 1953.
- Petition for Certiorari: Allied Investigation Bureau, Inc. filed a petition for certiorari, challenging the computation of retirement benefits and arguing that the benefits should only apply from the effectivity of the Labor Code in 1974.
Issue:
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Ruling:
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Ratio:
- Social Legislation Interpretation: Social legislation, such as the Labor Code, should be interpreted in favor of workers to align with the constitutional mandate of protection to labor and social justice.
- Retroactive Application of Laws: Police power legislation, including labor laws, applies to existing contracts and situations to promote public welfare. The retroactive application of retirement benefits is consistent with this principle.
- Equity and Fairness: The disparity between the company’s offer (P675.00) and the computed retirement pay (P7,762.50) highlights the need for equitable treatment of workers, especially considering the long years of service rendered by Velasquez.
- Constitutional Mandate: The 1935 and 1973 Constitutions emphasize the promotion of social justice and protection to labor, which justify the retroactive application of retirement benefits to ensure the economic security of workers.
Concurring Opinion (Justice Aquino)
Justice Aquino concurred, emphasizing that the award of retirement benefits is an act of social justice. He noted that the Termination Pay Law supports the award, and the retroactive application of benefits aligns with the principle that those who have less in life should have more in law.