Case Digest (G.R. No. 166507)
Facts:
The case involves a petition for review on certiorari filed by Amkor Technology Philippines, Inc., Anthony Michael Petrucci, and Rosemarie S. Katalbas (petitioners) against Nory A. Juangco (respondent). The events leading to the case began in September 1990 when Juangco was employed by Amkor Technology as a production control senior supervisor, eventually rising to the position of production control executive director with a monthly salary of P220,000.00. Throughout her tenure, she received merit increases and bonuses for her performance. In October 2001, following the resignation of her immediate superior, Tony Ng, Petrucci was appointed as president and initiated significant changes in corporate policies and management structure. On November 15, 2001, during an emergency meeting, Juangco was informed of a staff reorganization, which effectively terminated her employment. She was presented with a document to sign, which outlined the conditions of her alleged voluntary retire...
Case Digest (G.R. No. 166507)
Facts:
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.
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.
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.
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.
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.
NLRC Decision
- The National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, dismissing respondent's complaint.
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:
- Whether respondent was illegally dismissed from employment.
- 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.