Case Digest (G.R. No. 168987)
Facts:
In Catherine Dela Cruz-Cagampan v. One Network Bank, Inc., G.R. No. 217414, decided on June 22, 2022, petitioner Catherine Dela Cruz-Cagampan was hired by One Network Bank, Inc. as an Accounting Specialist on June 11, 2004. On May 1, 2006, the bank enacted an “Exogamy Policy”, mandating that married co-employees could not both remain employed and that one must terminate employment upon marriage. On October 31, 2009, Catherine married her coworker Audie Angelo A. Cagampan, a Loan Specialist. They sought permission to continue their employment under the same terms granted to pre-existing married employees; the request was denied by HR Head Myrna S. Viado and bank President Alex V. Buenaventura, and Catherine was dismissed on November 10, 2009. Catherine filed for reconsideration and, when rebuffed, filed a complaint for illegal dismissal before the Labor Arbiter. On October 29, 2010, the Arbiter ruled her dismissal illegal and ordered her reinstatement and payment of backwages andCase Digest (G.R. No. 168987)
Facts:
- Employment and Policy Enactment
- Catherine Dela Cruz-Cagampan was hired on June 11, 2004 as an Accounting Specialist by One Network Bank, Inc.
- On May 1, 2006, the Bank implemented its “Exogamy Policy,” providing that when two employees marry after that date, one spouse must terminate employment immediately (existing married employees at end-April 2006 were exempt).
- Marriage and Termination
- On October 31, 2009, Catherine married co-employee Audie Angelo A. Cagampan (Loan Specialist).
- On November 4, 2009, the couple requested permission to both remain employed; on November 10, 2009, HR Head Myrna S. Viado denied the request and terminated Catherine under the policy.
- Administrative and Judicial Proceedings
- February 1, 2010: Catherine sought reconsideration, arguing the policy’s non-retroactivity and its violation of Article 134 of the Labor Code; the Bank denied relief.
- October 29, 2010: The Labor Arbiter ruled Catherine was illegally dismissed, ordering her reinstatement with full backwages (tentatively ₱100,690.85) and proportional 13th-month pay.
- June 30, 2011: The NLRC affirmed, holding the Bank failed to prove any legitimate business necessity for the policy.
- July 31, 2014: The Court of Appeals granted the Bank’s certiorari petition, reversed the NLRC and Labor Arbiter, upheld the policy as a valid exercise of management prerogative (bona fide occupational qualification), and awarded Catherine separation pay (plus ₱30,000 nominal damages for procedural due-process lapse).
- February 10, 2015: The CA denied Catherine’s motion for reconsideration.
- Catherine filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, challenging the CA’s reversal of the finding of illegal dismissal and the legality of the Exogamy Policy.
Issues:
- Jurisdiction and Procedural Timeliness
- Whether the Court of Appeals correctly entertained the Bank’s petition for certiorari despite alleged delay.
- Legality of the Exogamy Policy
- Whether the Bank’s no-spouse employment rule constitutes unlawful discrimination against a woman employee under Article 134 of the Labor Code.
- Whether the Bank established, by substantial evidence, a reasonable business necessity (bona fide occupational qualification) justifying the policy.
- Appropriate Remedy
- What relief is due an employee found to be illegally dismissed under the Labor Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)