Title
Beltran vs. AMA Computer College-Binan
Case
G.R. No. 223795
Decision Date
Apr 3, 2019
Quintin V. Beltran, a former employee of AMA Computer College, successfully sues for early retirement benefits after providing evidence of a consistent company practice, resulting in the court awarding him various monetary damages.
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Case Digest (G.R. No. 223795)

Facts:

  • Quintin V. Beltran was the Chief Operations Officer (COO) of AMA Computer College in Biñan, Laguna.
  • He began his career with the AMA Education System in June 1990 as a Mathematics and CAD Instructor.
  • Beltran was promoted through various roles, ultimately becoming COO in January 1999.
  • In 2008, he sought early retirement based on a company policy that allowed such benefits.
  • His application was verbally approved, but he left for the United States on June 3, 2008, before receiving formal documentation.
  • Upon his return in September 2010, Beltran filed a complaint for retirement benefits and other monetary claims against AMA and its officials.
  • AMA acknowledged his employment but contested the existence of a formal early retirement policy, claiming his application was disapproved prior to his departure.
  • The Labor Arbiter dismissed his complaint due to insufficient evidence of the policy's existence.
  • The National Labor Relations Commission (NLRC) partially granted his appeal regarding unpaid salary but denied his claim for retirement benefits.
  • The Court of Appeals (CA) upheld the NLRC's decision, prompting Beltran to file a petition for review.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court granted Beltran's petition, reversing the decisions of both the Court of Appeals and the NLRC.
  • The Court determined that Beltran was entitled to early retirement benefits, supported by substantial evidence of a consistent practice within the company....(Unlock)

Ratio:

  • The Supreme Court highlighted that the burden of proof in labor cases rests with the claimant, necessitating substantial evidence.
  • The Court criticized the NLRC and CA for failing to adequately consider affidavits from former employees that confirmed a consistent practice of granting early retirement benefits to employees with at least ten years of service.
  • Procedural rules in labor cases perm...continue reading

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