Title
Amkor Technology Philippines, Inc. vs. Juangco
Case
G.R. No. 166507
Decision Date
Sep 27, 2006
Employee terminated during reorganization; claimed illegal dismissal. Court ruled in her favor, awarding separation pay and backwages, but denied moral/exemplary damages due to lack of proof.
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Case Digest (G.R. No. 166507)

Facts:

  1. Employment Background

    • Nory A. Juangco (respondent) was employed by Amkor Technology Philippines, Inc. (petitioner company) in September 1990 as a production control senior supervisor.
    • She was later promoted to the position of production control executive director with a monthly salary of P220,000.00.
    • During her tenure, she received merit increases and bonuses for her exemplary performance.
  2. Change in Management

    • In October 2001, Tony Ng, respondent's immediate superior, resigned and was replaced by Anthony Michael Petrucci (petitioner) as president.
    • The new management implemented drastic changes in corporate policies and the management team.
  3. Termination of Employment

    • On November 15, 2001, during an emergency meeting, petitioners informed respondent of a staff reorganization and terminated her services effective immediately.
    • She was directed to sign a document outlining the conditions of her alleged voluntary retirement, including:
      • Payment of separation benefits at the rate of 11/4 months basic salary per year of service.
      • Additional two months basic salary in lieu of the one-month notice requirement.
      • Forfeiture of separation benefits if company rules on confidentiality and operational disruption were violated.
    • She was ordered to leave the company and, on November 21, 2001, was forced to sign a "Release and Quitclaim" after receiving her separation benefits.
  4. Petitioners' Defense

    • Petitioners claimed that due to an economic slowdown, they implemented cost-cutting measures, including a retrenchment program.
    • They alleged that respondent voluntarily submitted herself for retrenchment and tendered her resignation letter.
    • She was paid P3,704,517.98 as separation benefits, two months' salary, leave credits, 13th month pay, and coop receivable.
    • She executed a "Release and Quitclaim" on November 22, 2001.
  5. Labor Arbiter's Decision

    • The Labor Arbiter ruled that respondent was illegally dismissed and ordered her reinstatement with full backwages, damages, and attorney's fees.
  6. NLRC Decision

    • The National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, dismissing respondent's complaint.
  7. Court of Appeals Decision

    • The Court of Appeals reinstated the Labor Arbiter's decision but modified it by awarding separation pay in lieu of reinstatement and reducing moral and exemplary damages.

Issue:

  1. Whether respondent was illegally dismissed from employment.
  2. Whether respondent is entitled to separation pay, backwages, damages, and attorney's fees.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court denied the petition and affirmed the Court of Appeals' decision with modification, deleting the awards for moral and exemplary damages.


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