Case Digest (G.R. No. 192105)
Facts:
In Antonio Locsin II vs. Mekeni Food Corporation (G.R. No. 192105, December 9, 2013), petitioner Antonio Locsin II was hired on March 17, 2004 as Regional Sales Manager of respondent Mekeni Food Corporation. His compensation package included a car plan under which Mekeni would cover half the cost of a used Honda Civic (valued at ₱280,000) and the balance would be deducted from his salary at ₱5,000 per month. Locsin resigned effective February 25, 2006, by which time he had contributed ₱112,500; he returned the vehicle on May 2, 2006 after negotiations to purchase it failed. Respondent then claimed that only employees with five years’ service could fully enjoy the car plan and demanded payment of ₱116,380 as balance. On May 3, 2007, Locsin filed a complaint with the NLRC for unpaid salaries, commissions, leave benefits, and reimbursement of his car plan contributions. The Labor Arbiter ordered turnover of the vehicle upon payment of ₱100,435.84. On appeal, the NLRC awarded unpaid...Case Digest (G.R. No. 192105)
Facts:
- Background and Offer
- In February 2004, Mekeni Food Corporation (a Philippine food manufacturer) offered Antonio Locsin II the position of Regional Sales Manager, covering National Capital Region Supermarket/Food Service and South Luzon operations.
- The written Offer Sheet included a compensation and benefits package, among which was a “car plan” under which Mekeni would pay half the cost of a service vehicle and the employee the other half via monthly salary deductions.
- Car Plan Implementation and Resignation
- Locsin commenced employment on March 17, 2004, and was provided a used Honda Civic valued at ₱280,000 (previously used by his supervisor).
- His 50% share (₱140,000) was to be paid through ₱5,000 monthly deductions; by his resignation effective February 25, 2006, a total of ₱112,500 had been deducted and Mekeni purportedly matched that amount.
- Locsin offered to pay the outstanding balance to purchase the vehicle; negotiations failed, and he returned the car on May 2, 2006.
- Administrative and Judicial Proceedings
- Mekeni claimed the car plan benefit applied only after five years of service and asserted Locsin owed ₱116,380 if he wished to purchase the vehicle.
- On May 3, 2007, Locsin filed with the NLRC (NCR, Quezon City; NLRC Case No. 00-05-04139-07) a complaint for unpaid salaries, commissions, leave benefits, and reimbursement of car plan deductions.
- Labor Arbiter and NLRC Decisions
- October 30, 2007: Labor Arbiter Ramos ordered Mekeni to turn over the vehicle upon Locsin’s payment of ₱100,435.84.
- February 27, 2009: The NLRC reversed the Arbiter and ordered Mekeni to pay Locsin:
- Unpaid salary: ₱12,511.45
- Unpaid sick/vacation leave pay: ₱14,789.15
- Unpaid commissions: ₱9,780.00
- Reimbursement of employee’s car plan payments: ₱112,500.00
- Company’s share under the car plan (as benefit): ₱112,500.00
- Less authorized deduction (cash advance): ₱4,736.50
- The NLRC held that both the deducted payments and the company’s counterpart share formed part of Locsin’s employment benefits; Mekeni’s five-year claim lacked proof.
- Court of Appeals Proceedings
- Mekeni petitioned for certiorari with the CA (CA-G.R. SP No. 109550).
- January 27, 2010: The CA granted the petition in part, deleting the NLRC’s award of both the reimbursement of the ₱112,500 car plan payments and the ₱112,500 company share; it treated the employee’s contributions as forfeited rentals under Civil Code Arts. 1484–1486 (citing Elisco Tool Mfg. Corp. v. CA).
- April 23, 2010: The CA denied Locsin’s motion for partial reconsideration.
Issues:
- Car Plan Payments
- Whether the Court of Appeals erred in treating Locsin’s ₱112,500 car plan deductions as forfeited rentals rather than refundable contributions forming part of his compensation package, in the absence of any stipulation to that effect.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)