Title
Beralde vs. Lapanday Agricultural and Development Corp.
Case
G.R. No. 205685-86
Decision Date
Jun 22, 2015
Lapanday retrenched employees in 2008, citing financial losses. Petitioners claimed illegal dismissal, but courts upheld retrenchment as valid, citing audited losses and procedural compliance, granting separation pay.
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Case Digest (G.R. No. 205685-86)

Facts:

  1. Background of the Case:

    • Lapanday Agricultural and Development Corporation (Lapanday) is engaged in banana plantation and export operations.
    • Petitioners are employees of Lapanday who were retrenched in 2008 as part of a retrenchment program.
  2. Initial Retrenchment and Rehiring (1992-1994):

    • Between 1992-1994, Lapanday retrenched some employees and paid separation benefits.
    • Some employees were rehired with a promise that the land they worked on would be turned over to them under the Comprehensive Agrarian Reform Program (CARP).
  3. Second Retrenchment (1999):

    • In 1999, Lapanday retrenched all employees and offered separation pay.
    • The Department of Agrarian Reform (DAR) issued an order exempting the land from CARP coverage, preventing the promised turnover.
    • Employees, including petitioners, signed new employment contracts but later filed a petition to revoke the DAR exemption order.
  4. 2008 Retrenchment Program:

    • On January 4, 2008, Lapanday issued a Notice of Termination to all employees, citing financial difficulties due to increased production costs, lower productivity, and other economic challenges.
    • The termination was effective February 4, 2008.
    • Some employees signed the notice, but petitioners refused, alleging they were not given separation pay and were barred from entering the premises unless they signed.
  5. Legal Proceedings:

    • Petitioners filed complaints for illegal dismissal in 2008.
    • Lapanday claimed financial losses, citing audited financial statements showing significant losses in 2006 and 2007.
    • The Labor Arbiter initially ruled in favor of Lapanday, declaring the retrenchment valid and ordering payment of separation pay.
    • The National Labor Relations Commission (NLRC) reversed the decision, declaring the dismissal illegal and ordering reinstatement with backwages.
    • The Court of Appeals reinstated the Labor Arbiter’s decision, finding the retrenchment valid.

Issue:

  1. Whether Lapanday’s retrenchment program was valid and complied with legal requirements.
  2. Whether the petitioners were illegally dismissed.
  3. Whether Lapanday’s financial losses justified the retrenchment.
  4. Whether the rehiring of some employees after retrenchment negated the validity of the retrenchment program.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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