G.R. No. 152928 - Metropolitan Bank and Trust Co. vs. National Labor Relations Commission

Metropolitan Bank and Trust Company was the employer-petitioner.
Felipe A. Patag was an Assistant Manager who compulsorily retired on February 1, 1998, with a monthly salary of P32,100.00 and received total retirement benefits of P1,957,782.71 under the 1995 Officers' Benefits Memorandum computed at 185% per year of service.
Bienvenido C. Flora was a Senior Manager who compulsorily retired on April 1, 1998, with a monthly salary of P48,500.00 and received total retirement benefits of P3,042,934.29 under the 1995 Officers' Benefits Memorandum computed at 185% per year of service.

Patag wrote a letter dated February 2, 1998 requesting that his retirement benefits be computed at any new increased rate that might result from the 1998-2000 CBA negotiations.
Flora wrote Metrobank on March 25, 1998 requesting computation of his retirement benefits at the increased rate of 200% as embodied in the just concluded CBA between the bank and its rank and file.
Metrobank did not reply to the initial requests; respondents alleged a consistent practice by Metrobank since 1986 of issuing Officers' Benefits memoranda after each CBA that granted officers benefits similar to or better than those in the rank-and-file CBA, retroactive to January 1 of the applicable year.

Upon approval of the 1998-2000 CBA, Metrobank issued an Officers' Benefits Memorandum dated June 10, 1998, signed by President Antonio S. Abacan, Jr., increasing compulsory retirement benefits from 185% to 200% effective January 1, 1998, but conditioned eligibility on officers remaining in service as of June 15, 1998.
Flora wrote on June 29, 1998 seeking reconsideration of the June 15, 1998 employment condition; Metrobank denied reconsideration in a July 17, 1998 reply.
On August 31, 1998, Patag and Flora, through counsel, demanded payment of unpaid additional retirement benefits amounting to P284,150.00 and P448,050.00 respectively; Metrobank replied on September 17, 1998 declaring them ineligible because they had ceased employment before June 15, 1998.

On September 25, 1998, Patag and Flora filed a consolidated complaint with the Labor Arbiter for underpayment of retirement benefits and damages; Patag also claimed 1997 profit share and 1998 ...(Subscriber-Only)

Whether respondents were entitled to additional retirement benefits under the June 10, 1998 Officers' Benefits Memorandum despite having compulsorily retired before its issuance and not meeting the June 15, 1998 employment condition.
Whether the NLRC and the Court of Appeals correctly found that Metrobank's prior memoranda and conduct from 1986 to 1997 established a company practice or policy of granting improved officers' benefits retroactive to January 1 without any condition as to continued employment.
Whether respondents were estopped or legally barred from claiming additional benefits by virtue of their unqualified receipt of retirement payments or any quitclaim or release.
Whether the imposition of the June 15, 1998 condition and denial to respondents resulted in impermissible d...(Subscriber-Only)