Case Digest (G.R. No. 73287)
Facts:
International Harvester Macleod, Inc. v. Hon. Intermediate Appellate Court & Diosdado L. Joson, G.R. No. 73287, May 18, 1987, Supreme Court Second Division, Paras, J., writing for the Court.The petitioner is International Harvester Macleod, Inc. (IHMI); the private respondent is Diosdado L. Joson, formerly employed by IHMI. Joson began working for IHMI in July 1960 and rose through various positions until his appointment in May 1975 as Government Relations Officer in the Government Sales Department with a monthly salary of P2,500.00. In July 1977 IHMI (through Vice‑President Eduard Lim) informed Joson that his Government Relations Officer position had become redundant because IHMI had engaged International Heavy Equipment Corporation (IHEC) as its government dealer; Joson was offered transfer to Fleet Account Salesman at a reduced basic salary but with commission opportunities. Joson refused the transfer and was given a check representing termination pay, which he accepted while writing a reservation that acceptance was "without prejudice and with reservations."
Joson filed Civil Case No. 110444 in the Court of First Instance (CFI) of Manila for damages for alleged illegal termination against IHMI and two officers, Richard Quinlan and Eduard Lim. IHMI moved to dismiss for lack of jurisdiction (arguing labor jurisdiction), but the CFI denied the motion on October 26, 1977, treating the action as principally civil. A pre‑trial default was declared against IHMI for failure to appear; that default was later set aside but the court ordered that the ex parte testimony presented should stand and that IHMI had waived cross‑examination. IHMI filed a petition for certiorari and prohibition with the Intermediate Appellate Court (IAC), which issued a temporary restraining order but ultimately denied the petition on September 1, 1978 and denied reconsideration.
After trial the CFI, in a decision written by Judge Alfredo C. Florendo, found IHMI liable for illegal termination and awarded P800,000 moral damages, P200,000 exemplary damages, and attorney’s fees and costs; the case against Quinlan and Lim was dismissed. The Court of Appeals (Intermediate Appellate C...(Subscriber-Only)
Issues:
- Did the trial court commit a manifestly erroneous inference of fact in finding that Joson’s position had not become redundant?
- Did the trial court err in failing to recognize the legal effect of redundancy when IHMI offered Joson an alternative position?
- Did the trial court improperly rely on speculation regarding why Joson accepted the termination check and thereby ignore any compromise between the parties?
- Was the award of moral and exemplary damages, attorney’s fees and costs supported by proof of fraud, bad faith or gross negligence, or was the award excessive?
- Did the low...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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