Case Digest (G.R. No. 163788)
Facts:
- Ester B. Maralit was employed by the Philippine National Bank (PNB) from August 27, 1968, to December 31, 1998.
- She progressed from a casual clerk to a branch manager during her tenure.
- In February 1998, PNB introduced the Special Separation Incentive Plan (SSIP), approved by Board Resolution No. 1.
- SSIP guidelines allowed employees with pending administrative cases to apply, but benefits would be paid only after case resolution.
- On September 8, 1998, PNB's Internal Audit Group reported Maralit for violating bank policies, involving unfunded checks totaling P54,950,000.
- Maralit applied for early retirement on September 15, 1998, after being charged with serious misconduct on September 29, 1998.
- She was placed under preventive suspension on October 16, 1998.
- PNB conditionally approved her retirement on November 20, 1998, pending the outcome of her administrative case.
- On February 14, 2000, she was found guilty of serious misconduct and dismissed, forfeiting her retirement benefits.
- Maralit filed a complaint with the National Labor Relations Commission (NLRC) for non-payment of retirement benefits and damages.
- The Labor Arbiter ruled in her favor, awarding benefits and damages, but the NLRC modified the decision, deleting damages.
- PNB appealed to the Court of Appeals, which set aside the NLRC's resolution, leading to the current petition.
Issue:
- (Unlock)
Ruling:
- The Supreme Court denied Maralit’s petition and affirmed the Court of Appeals' decision, which set aside the NLRC's resolution.
- The Court held that the NLRC did not commit grave abuse of discretion and that...(Unlock)
Ratio:
- The Supreme Court reasoned that the NLRC's review power does not exclude the possibility of grave abuse of discretion.
- The NLRC acted within its authority, and the Labor Arbiter'...continue reading
Case Digest (G.R. No. 163788)
Facts:
Ester B. Maralit (Petitioner) was employed by the Philippine National Bank (PNB) from August 27, 1968, until December 31, 1998. She started as a casual clerk and eventually became a branch manager. In February 1998, PNB introduced an early retirement plan known as the Special Separation Incentive Plan (SSIP), which was approved by the bank's Board Resolution No. 1. The guidelines for the SSIP, outlined in General Circular No. 1-355/98, allowed employees with pending administrative cases to apply for the plan, but benefits would only be paid after the resolution of their cases, provided they were not disqualified from receiving such benefits.
On September 8, 1998, PNB's Internal Audit Group (IAG) reported that Maralit had violated bank policies, leading to the return of unfunded checks totaling P54,950,000. Following this, Maralit applied for early retirement on September 15, 1998. On September 29, 1998, PNB charged her with serious misconduct and gross violation of bank rules. Subsequently, she was placed under preventive suspension on October 16, 1998. PNB conditionally approved her retirement on November 20, 1998, stating that payment of her retirement benefits would depend on the resolution of the administrative case against her.
On February 14, 2000, PNB's Administrative Adjudication Panel found Maralit guilty of serious misconduct and dismissed her from service, forfeiting her retirement benefits. Maralit then filed a complaint with the National Labor Relations Commission (NLRC) for non-payme...