Case Digest (G.R. No. 175293)
Case Digest (G.R. No. 175293)
Facts:
Crisanto F. Castro, Jr. v. Ateneo de Naga University, Fr. Joel Tabora, and Mr. Edwin Bernal, G.R. No. 175293, July 23, 2014, the Supreme Court First Division, Bersamin, J., writing for the Court.The petitioner, Crisanto F. Castro, Jr., was a regular, full‑time faculty member of the Ateneo de Naga University (the University) with a monthly salary of P29,846.20. The University notified him on February 22, 2000 that his contract (expiring May 31, 2000) would not be renewed; thereafter he received no teaching load effective June 2000 and filed a complaint for illegal dismissal.
On September 3, 2001, Labor Arbiter (LA) Jesus Orlando M. Quinones ruled for the petitioner, declaring the dismissal illegal, ordering reinstatement (or payroll reinstatement at the employer’s option), awarding full backwages (Php 637,999.65), moral and exemplary damages (Php 500,000.00) and attorney’s fees. The respondents appealed to the National Labor Relations Commission (NLRC) and filed a manifestation that actual or payroll reinstatement could not be effected because the petitioner had accepted government employment as a Presidential Assistant/Undersecretary, raising concerns of dual compensation.
In July–October 2002 procedural skirmishing followed: the petitioner asked enforcement of the LA decision; the LA directed respondents to exercise their option—actual or payroll reinstatement—within ten days, otherwise the petitioner’s motion for accrued salaries would be appropriate. The petitioner was reinstated in November 2002, according to respondents.
While the NLRC initially affirmed with modification, on August 31, 2005 the NLRC reversed and dismissed the illegal dismissal complaint. The NLRC rested that dismissal largely on the petitioner’s June 26, 2004 execution of a receipt and quitclaim for P646,828.42 representing payment “pursuant to the Employees retirement plan,” reasoning that the quitclaim estopped him from pursuing further money claims arising out of employment.
The petitioner had, however, contemporaneously sent a June 29, 2004 letter stating that he accepted the retirement payment “UNDER PROTEST” and that the receipt and quitclaim were forced by the University’s Treasurer and counsel and that he did not agree with the computation of years of service.
The Court of Appeals (CA) dismissed the petitioner’s petition for certiorari as moot and academic on May 31, 2006, reasoning that the NLRC’s August 31, 2005 decision had rendered the CA petition moot. The petitioner sought relief in the Supreme Court, contending (inter alia) that the quitclaim covered only retirement benefits and did not bar his claim for accrued salaries resulting from respondents’ failure to implement the LA’s reinstatement order; he relied on Roquero v. Philippine Airlines, Inc. and other authorities holding that reinstatement orders are immediately executory and that wages accrue while an employer unjustifiably refuses reinstatement.
Issues:
- Did the petitioner’s execution of the June 26, 2004 receipt and quitclaim bar his claim for accrued salaries and benefits arising from the LA’s reinstatement order?
- Was the petitioner’s claim for accrued salaries and benefits rendered moot and academic by the NLRC’s August 31, 2005 dismissal of his illegal dismissal complaint?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)