Facts:

The case involves Amkor Technology Philippines, Inc., represented by Anthony Michael Petrucci and Rosemarie S. Katalbas as petitioners, and Nory A. Juangco as the respondent. The events leading to the case unfolded in 2001 when Amkor Technology, facing business losses, decided to implement a voluntary retirement program. In October 2001, a meeting was convened with key officers, including Juangco, to discuss the downsizing strategy. During this meeting, Juangco expressed her willingness to participate in the voluntary retirement program. Subsequently, she submitted an undated letter indicating her intention to retire effective November 15, 2001, and outlined her expected separation package, which included 1.25 months of pay for each year of service and an additional two months' pay. On November 22, 2001, she received a retirement package totaling P3,704,517.98 and signed a Receipt and Release Waiver and Quitclaim.

However, Juangco later claimed that she was coerced int...

Facts:

Context and Background

• The case involves petitioner Amkor Technology Philippines, Inc. and its executives versus respondent Nory A. Juangco concerning her retirement from the company.
• The company experienced business losses, prompting a need to reduce its manpower, which led to discussions among officers and department heads about either a voluntary retirement/voluntary separation program or a retrenchment program.

The Meeting and Initiation of the Retirement Process

• In October 2001, key officers and department heads—including respondent—were convened to decide on the implementation of a downsizing program.
• During the meeting, respondent voluntarily expressed her interest in participating in the downsizing, indicating her availability to retire from her position as Executive Director.

Execution of the Retirement Arrangement

• Respondent submitted an undated letter signifying her intention to avail of the company’s Voluntary Retirement Program, with an effective date of November 15, 2001.
• The terms of the retirement were clearly stated, providing:
• A separation package equivalent to 1.25 months of her current basic monthly salary per year of service.
• An additional one-time two-month pay, which is inclusive of the legally mandated 30-day notice pay.
• On November 22, 2001, respondent received her retirement package amounting to Three Million Seven Hundred Four Thousand Five Hundred Seventeen Pesos and 98/100 (P3,704,517.98).
• On the same day, respondent signed a Receipt and Release Waiver and Quitclaim.

Controversy and Allegations

• The central issue arose from the contention whether respondent’s retirement was truly voluntary.
• Respondent later alleged that she was coerced into signing the retirement letter under duress and intimidation; she claimed that she was threatened with receiving nothing if she did not sign the waiver.
• Petitioners, on the other hand, maintained that her resignation was voluntary and, therefore, no illegal dismissal occurred.

Evidentiary Basis and Testimonies

• The voluntary nature of the retirement was attested by the top-ranking officials of the company who were present during the October 2001 meeting.
• No contradictory evidence was presented by the respondent to challenge the testimonies of the company officials.
• Records showed that respondent received her retrenchment backwages shortly after submitting her resignation, and subsequently, she sought employment with another company.
• The timeline indicated a significant delay in filing her complaint for illegal dismissal, which was submitted almost six months after her separation.

Issue:

Whether respondent voluntarily executed her retirement or whether she was coerced/intimidated into signing the Receipt and Release Waiver and Quitclaim.

• Determining if the manifest evidence supports the allegation of duress and intimidation.
• Evaluating the consistency and credibility of the testimonies from both the NLRC figures and the Court of Appeals.

• The appropriate interpretation of the evidence in light of the applicant's educational and professional background, and whether such a person could be easily manipulated into signing a document that affects her rights.

• The impact of the timing of her filing the complaint for illegal dismissal relative to the receipt of her retirement benefits, and whether such delay undermines the claim of duress.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)