Case Digest (G.R. No. 141868)
Facts:
In Jose B. Cruz, et al. v. Philippine Global Communications, Inc., G.R. No. 141868, May 28, 2004, the Supreme Court Third Division, Sandoval‑Gutierrez, J., writing for the Court, resolved whether retrenched employees who received separation pay may still claim retirement benefits.Petitioners (Jose B. Cruz, Rodolfo C. Delos Santos, Vicente A. Rigos, Gregorio A. Lingal and Alicia P. Francisco) were managerial, supervisory and confidential employees of Philippine Global Communications, Inc. (respondent). Due to declining telex/telegram volume and substantial losses in 1993–1994, respondent instituted an organizational streamlining program that closed branches and terminated 42 workers, including petitioners. In separate letters dated January 30, 1995, petitioners were notified of termination effective March 1, 1995; respondent paid them separation pay computed at 1½ months’ salary per year of service, and they executed a Release, Waiver and Quitclaim.
Despite having received separation pay, petitioners filed a complaint for payment of retirement benefits, damages and attorneys’ fees with the Labor Arbiter (docketed NLRC NCR Case No. 00‑10‑06979‑95). On July 31, 1997 the Labor Arbiter ruled in petitioners’ favor, awarding retirement benefits as provided by respondent’s Retirement Plan. The NLRC, however, reversed in a March 2, 1998 Decision and dismissed the complaint; a motion for reconsideration was denied. Petitioners initially filed a certiorari petition with the Court which was referred to the Court of Appeals pursuant to St. Martins Funeral Home v. NLRC; the Court of Appeals, in a July 30, 1999 Decision (CA‑G.R. SP No. 50654), affirmed the NLRC, holding that the Retirement Plan’s Section 6(b), Article XI precluded recovery of both separation pay and retirement benefits and that petitioners were entitled only to whichever benefit was greater. The Court of Appeals denied reconsideration by Resolution da...(Subscriber-Only)
Issues:
- Did the National Labor Relations Commission and the Court of Appeals act without or in excess of jurisdiction or with grave abuse of discretion warranting reversal of their findings?
- Are petitioners entitled to recover retirement benefits in addition to separation pay under respondent’s Retirement Plan, given the Plan’s provisions and Art...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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