Case Digest (G.R. No. 162021)
Facts:
Mega Magazine Publications, Inc., Jerry Tiu, and Sarita V. Yap v. Margaret A. Defensor, G.R. No. 162021, June 16, 2014, First Division of the Supreme Court, Bersamin, J., writing for the Court.Petitioner Mega Magazine Publications, Inc. (MMPI) employed respondent Margaret A. Defensor beginning in 1996 and promoted her to Group Publisher with a P60,000 monthly salary. In February and April 1999 the respondent circulated memoranda proposing an outright commission schedule and a special incentive plan tied to MMPI’s gross advertising revenues, and Yap made handwritten counter-proposals and asked the respondent to formalize the agreement. The respondent resigned effective December 1999; on December 8, 1999 Yap sent a memorandum formalizing her handwritten approval and setting a schedule that pegged commissions and group incentives to gross advertising revenues with payment conditions.
In May 2000 the respondent filed a complaint for payment of commissions, a 14th month pay, and an incentive share (total claimed then approximately P271,264.68 plus other items). The Labor Arbiter (LA) dismissed the complaint on February 5, 2001, finding no agreement on terms and relying on an audited statement by Punongbayan & Araullo showing lower gross revenues. The National Labor Relations Commission (NLRC) denied the respondent’s appeal and motions for reconsideration. The respondent filed a special civil action (certiorari) in the Court of Appeals (CA). The CA’s August 28, 2003 decision dismissed the petition, but on reconsideration the CA, in an amended decision promulgated November 19, 2003, granted the petition, annulled the NLRC resolutions, and remanded the case to the NLRC for reception of additional evidence while sustaining the LA’s denial of 14th month pay.
The petitioners and the respondent both sought reconsideration before the CA; the CA denied those motions on February 4, 2004. The petitioners then brought a petition for review on certiorari (Rule 45) to the Supreme Court, assailing (1) the CA’s allowance of evidence supposedly not newly discovered and (2) the CA’s remand t...(Pro-only)
Issues:
- Did the Court of Appeals correctly remand the case to the NLRC to permit reception of additional evidence that was not newly discovered?
- Was the respondent entitled to the commissions and the special incentive bonus she cla...(Pro-only)
Ruling:
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Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)