Case Digest (G.R. No. 217414)
Facts:
Catherine Dela Cruz‑Cagampan v. One Network Bank, Inc., G.R. No. 217414, June 22, 2022, Supreme Court Second Division, Leonen, SAJ., writing for the Court. Petitioner Catherine Dela Cruz‑Cagampan was hired by One Network Bank, Inc. on June 11, 2004 as an Accounting Specialist. On May 1, 2006, the bank implemented an “Exogamy Policy” (a no‑spouse employment rule) providing that when two employees subsequently marry, one must terminate employment immediately; the policy purportedly exempted couples already married as of April 2006. On October 31, 2009 Catherine married her co‑worker, Audie Angelo A. Cagampan, a Loan Specialist.After the marriage the couple sought permission from the bank president to continue employment (with the possibility of transferring Audie Angelo). On November 10, 2009, the Head of Human Resources denied the request and terminated Catherine’s employment; Audie Angelo’s employment was retained. Catherine sought reconsideration on February 1, 2010, arguing the policy could not be applied to her (she was employed before its effectivity) and that it violated Article 136 (now Article 134) of the Labor Code prohibiting discrimination based on marriage. Reconsideration was denied and Catherine filed a complaint for illegal dismissal.
The Labor Arbiter, in a Decision dated October 29, 2010, declared Catherine illegally dismissed, ordered reinstatement and payment of backwages and benefits (the Decision was immediately executory as to reinstatement). The National Labor Relations Commission (NLRC) affirmed in a June 30, 2011 Decision, finding the bank’s fear of disclosure of client information was speculative and that the bank failed to prove a legitimate business concern. The NLRC denied reconsideration on August 24, 2011.
One Network Bank filed a petition for certiorari with the Court of Appeals (CA); the CA initially denied a TRO but, in a July 31, 2014 Decision (Special Twenty‑Second Division, CA‑G.R. SP No. 04589‑MIN), granted the petition, held the no‑spouse policy was a valid exercise of management prerogative as a bona fide occupational qualification (BFOQ) for banks, and reversed the NLRC, declaring the dismissal substantively valid but awarding separation pay and nominal damages for procedural due‑process defects. Catherine’s motion for reconsideration before the CA was denied on February 10, 2015.
Catherine filed a Petition fo...(Pro-only)
Issues:
- Did the Court of Appeals correctly find that the National Labor Relations Commission committed grave abuse of discretion in affirming the Labor Arbiter’s ruling that Catherine was illegally dismissed?
- Was One Network Bank’s no‑spouse (exogamy) policy a lawful exercise of management prerogative justifying Catherine’s dismissal, or was the dismissal discriminatory and illegal under the Labor C...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)