Case Digest (G.R. No. 185346) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves two consolidated petitions filed before the Supreme Court: one by Banco Filipino Savings and Mortgage Bank (Banco Filipino) against Miguelito M. Lazaro (G.R. No. 185346) and another by Lazaro against Banco Filipino and other respondents (G.R. No. 185442). Both petitions arise from the Court of Appeals' decision on January 23, 2008, and resolution on November 12, 2008, in CA-G.R. SP No. 93145. Lazaro began his employment with Banco Filipino on February 1, 1968, and rose through the ranks to become an assistant manager until the bank's closure by the Central Bank of the Philippines on January 25, 1985. After some time, he was reemployed on April 16, 1992, as a member of a task force to collect delinquent accounts. Following a Supreme Court ruling deeming the bank's closure illegal, Banco Filipino reopened in June 1992. Lazaro continued to work until his retirement on December 1, 1995. Initially, he received retirement benefits reflecting only 20 years and 7 month Case Digest (G.R. No. 185346) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment History:
- Miguelito M. Lazaro began working for Banco Filipino on 1 February 1968 as a probationary employee. He rose to the position of assistant manager and continued working until the bank was closed by the Central Bank of the Philippines on 25 January 1985.
- After the bank's closure, Lazaro was reemployed on 16 April 1992 as part of a task force assigned to collect delinquent accounts.
- Following the Supreme Court's ruling that the bank's closure was illegal, Banco Filipino reopened in June 1992. Lazaro continued working until his retirement on 1 December 1995 as an assistant vice-president.
- Retirement Benefits:
- Lazaro was paid retirement benefits for 20 years and 7 months of service, based on his final salary of ₱38,000 per month.
- Lazaro contested this, claiming he should be credited with 27 years and 10 months of service and that his retirement pay should be based on a salary of ₱50,000, reflecting a salary increase granted to senior officers in December 1995.
- Additional Claims:
- Lazaro demanded 10% attorney’s fees from foreclosure proceedings he handled and a 10% profit share from 1984 to 1995.
- Banco Filipino denied these claims, arguing that Lazaro was already compensated for his work as legal counsel and that profit shares required Monetary Board approval.
- Labor Arbiter and NLRC Decisions:
- The Labor Arbiter (LA) denied Lazaro’s claims, and the National Labor Relations Commission (NLRC) affirmed this decision.
- Court of Appeals Decision:
- The CA granted Lazaro a retirement pay differential for the 7 years the bank was under liquidation but denied his claims for attorney’s fees, profit shares, and a higher salary base for retirement pay.
Issues:
- Whether the CA erred in granting Lazaro a retirement pay differential for the 7-year liquidation period.
- Whether the CA erred in dismissing Lazaro’s claims for attorney’s fees and profit shares.
- Whether the CA erred in not addressing Lazaro’s claims for a one-day salary differential and damages (moral, exemplary, attorney’s fees, and expenses of suit).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)