G.R. No. 213486 - Catotocan vs. Lourdes School of Quezon City, Inc.

Editha M. Catotocan began working at Lourdes School of Quezon City (LSQC) in 1971 as a music teacher, earning a monthly salary of Php30,081.00.
By the school year 2005-2006, she had served the school for 35 years.
LSQC maintained a retirement plan that provided for retirement either at 60 years of age or upon completion of 30 years of service, whichever occurred first.

On November 25, 2003, LSQC issued Administrative Order No. 2003-004 as an addendum to its retirement policy, clearly stating that normal retirement would take effect either when an employee reached 60 years of age or completed 30 years of service—whichever came first.
In March 2004, Catotocan and seven co-employees formally appealed to the Provincial Minister and the Provincial Council on Education of LSQC, requesting deferment of the new “30 years of service” retirement requirement in favor of retiring at the age of 60, so they could fully enjoy the fruits of their labor.
In a reply dated April 25, 2004, Fr. Troadio de los Santos, LSQC Provincial Minister and Chairman of the Board, affirmed that the contested retirement age was consistent with other schools’ retirement plans.
Later, in a September 2004 letter, the employees presented survey results from other private schools showing that the retirement age was 60 regardless of the years of service, further contesting the new provision.

On October 12, 2004, Fr. Troadio de los Santos advised the employees to wait for the resolution of an already pending NLRC arbitration case (Tiongson v. LSQC).
On October 26, 2004, the employees sought the intervention of the Department of Labor and Employment-National Capital Region (DOLE-NCR), which referred the matter to Atty. Jose Mari Villaflor of the Public Assistance and Complaints Unit (PACU).
A meeting was held on November 22, 2004, between Catotocan, other affected teachers, and LSQC officials, during which it was suggested that compulsory retirement might equate to constructive dismissal.
A rescheduled meeting in January 2005 was not attended by the school officials.

On January 27, 2005, LSQC Rector Fr. Cesar Acuin sent a letter to Catotocan notifying her that, having rendered at least 30 years of service, she would be retired with a computed retirement benefit of Php1,052,835.00.
At that time, Catotocan was 56 years old.
The retirement benefits were disbursed in two parts: 60% (Php571,701.00) was paid as a lump sum via Banco De Oro (BDO), while the remaining 40% (Php421,134.00) was divided into 36 equal monthly installments.
In the same letter, Catotocan was given the option to continue serving LSQC on a contractual basis, to which she responded by submitting a “Letter of Intent” on February 14, 2006.

On May 11, 2006, LSQC appointed Catotocan as a Grade School Guidance Counselor for the school year 2006-2007 under a contractual arrangement.
Catotocan and other retirees were also included in the school’s Valucare Health Maintenance Plan, as requested in a letter dated August 16, 2006.
She was re-appointed in subsequent school years (2007-2008 and 2008-2009) as a Guidance Counselor, although her application for the position in January 2009 was declined.
Her actions—such as opening a BDO savings account for her retirement funds, accepting the full retirement benefit, and subsequently reapplying for a teaching position—are significant in establishing her conduct post-retirement.

On June 25, 2009, Catotocan filed a complaint with the NLRC alleging illegal dismissal and other monetary claims (e.g., step increment, moral and exemplary damages, attorney’s fees).
The Labor Arbiter, in a decision on March 26, 2010, dismissed her complaint for lack of merit, noting that her acceptance of the retirement benefits demonstrated implied consent to the new retirement policy.
The NLRC affirmed the Labor Arbiter’s ruling on October 20, 2010, and a subsequent resolution on May 13, 2011.
Dissatisfied with these decisions, Catotocan petitioned the Court of Appeals, which dismissed her petition on October 29, 2013.
Ultimately, on April 26, 2017, the Supreme Court affirmed the decisions of the Court of Appeals and the NLRC, thereby upholding LSQC’s retirement policy and dismissing the illegal dismissal claim.

Whether the Court of Appeals committed grave abuse of discretion by not applying the principle of stare decisis, given the existence of a prior decision on a similar forced retirement issue involving LSQC.
Whether the finding that Catotocan retired by acquiescence or by implication—evidenced by her opening a bank account to receive retirement benefits and accepting 3 years of contractual employment—was contrary to the established jurisprudence (i.e., the Jaculbe and Cercado cases), which require explicit, unambiguous assent to early retirement.
Whether the doctrine of estoppel should bar Catotocan from contesting the legality of her retirement and pursuing an illegal dismissal claim after having accepted her retirement benefits and subsequently re-employed.