Title
Cipriano vs. San Miguel Corporation
Case
G.R. No. L-24774
Decision Date
Aug 21, 1968
Employee retired due to health, received retirement benefits under union plan; court ruled benefits replaced separation pay under law, denying additional claims.

Case Digest (G.R. No. L-24774)

Facts:

  • Employment and Service Details
    • Plaintiff Raul Cipriano’s initial employment
      • Hired as an apprentice salesman of San Miguel Corporation on September 1, 1953, with a monthly salary of P215.
      • Became a regular salesman on March 1, 1954, with an increased monthly salary of P240.
    • Career advancement and salary increments
      • Received periodic promotions resulting in subsequent salary increases.
      • On January 1, 1963, his salary reached P290 per month.
      • From January 1, 1963, to April 17, 1964, he additionally earned an average monthly commission of P367.11.
  • Termination of Employment
    • Health-related retirement
      • On April 21, 1964, plaintiff received a notice stating that due to a medical certification deeming him unfit to continue his functions as a salesman, he would be retired.
      • The effective date of retirement was the close of business on April 17, 1964.
  • Benefits under the Health, Welfare and Retirement Plan
    • Membership and union agreement
      • Plaintiff was a member in good standing of the San Miguel Brewery Sales Force Union.
      • The union had entered into an agreement with San Miguel Corporation, dated February 20, 1963, establishing the "Health, Welfare and Retirement Plan."
    • Provisions of the plan
      • Section 2 of Article VIII stipulated retirement benefits at the rate of “one (1) month’s guaranteed basic compensation for each year of service.”
      • The computed total retirement benefit received by plaintiff was P2,292.28.
  • Separation Pay and Subsequent Claim
    • Plaintiff’s demand for additional benefits
      • Despite receiving retirement benefits under the union-agreed plan, plaintiff demanded payment of separation pay as prescribed by the Termination Pay Law.
      • Plaintiff further sought moral damages, exemplary damages, and attorney’s fees in connection with his claim.
    • Filing of the action
      • After the defendant’s failure to pay the demanded separation pay, plaintiff filed a complaint on December 1, 1964, to recover the separation pay and additional damages.
  • Contractual Provisions Delineating Benefits
    • Specific language of Article X of the union agreement
      • Provided that “regular employees who are separated from the service of the company for any reason other than misconduct or voluntary resignation shall be entitled to either 100% of the benefits provided in Section Article VIII hereof, regardless of their length of service in the company or to the severance pay provided by law, whichever is the greater amount.”
      • Implied that the employee may choose only one benefit option – either the computed retirement benefits under the plan or the statutory severance pay.

Issues:

  • Whether the retirement benefits provided by the union agreement under the "Health, Welfare and Retirement Plan" preclude the payment of additional termination (separation) pay as prescribed by the Termination Pay Law.
    • Does the language “either ... or” in Article X of the plan unequivocally bar the simultaneous payment of both benefits?
    • Is the plaintiff entitled to claim both the plan benefits and the statutory separation pay, or solely the one that amounts to the greater compensation?
  • Whether the exclusionary clause in the agreement is consistent with legal principles governing benefits entitlement during termination of employment.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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