Case Digest (G.R. No. 247775)
Facts:
Philippine Clearing House Corporation v. Alicia O. Magtaan, G.R. No. 247775, November 10, 2021, the Supreme Court Second Division, Inting, J., writing for the Court. The petition challenges the Court of Appeals Decision dated November 6, 2018 and Resolution dated June 3, 2019 in CA-G.R. SP No. 147435 affirming NLRC Resolutions (April 15 and June 30, 2016) that reversed the Labor Arbiter and declared respondent illegally dismissed.Philippine Clearing House Corporation (petitioner) hired Alicia O. Magtaan (respondent) in November 1998 as a secretary and assigned her to various offices, and on January 16, 2014 assigned her as Executive Assistant to Vice President for Operations Group Gil A. Lim. Confronted with rising manpower costs, the petitioner’s Board approved on January 30, 2014 a recommendation to implement a Manpower Rationalization Study (MRS) to evaluate manpower requirements; the Board, however, deferred final action pending further review of internal processes and table of organization. Through the purported MRS petitioner later concluded positions in the Operations Group—including respondent’s—were redundant.
VP Lim voluntarily resigned effective January 1, 2015. Petitioner issued a Notice dated February 2, 2015 terminating respondent due to redundancy effective March 31, 2015; it filed an Establishment Termination Report with DOLE on February 11, 2015 and paid respondent P528,071.00 (redundancy pay), P16,837.27 (net terminal leave), and P368,331.56 (net severance benefit), in exchange for a signed Deed of Release, Waiver, and Quitclaim. On May 22, 2015 respondent filed a complaint for illegal dismissal with the Labor Arbiter.
The Labor Arbiter, in a Decision dated December 28, 2015, ruled for petitioner, finding that the redundancy program complied with requisites and upholding the Quitclaim. Respondent sought reconsideration to the NLRC. The NLRC initially treated her pleading as a memorandum of appeal but dismissed it for non-perfection due to lack of verification and a certificate against forum shopping; respondent subsequently filed the missing verification and certificate and moved for reconsideration. In its April 15, 2016 Resolution the NLRC admitted the belated documents, reinstated the appeal, and reversed the Labor Arbiter, holding the dismissal illegal because (inter alia) VP Lim’s resignation did not render respondent’s position redundant, the unsigned and undated MRS lacked probative value, the HRD Manager’s affidavit was self-serving, and the Quitclaim did not bar the complaint. The NLRC ordered reinstatement, full backwages, moral and exemplary damages of P30,000.00 each, and attorney’s fees of 10% of the monetary award, allowing deduction of amounts already received.
Petitioner moved for partial reconsideration and for the first time submitted a signed MRS dated November 10, 2014 and a Board Resolution dated December 4, 2014. The NLRC denied admission of these belated documents and denied reconsideration in its June...(Pro-only)
Issues:
- Did the Court of Appeals err in upholding the NLRC’s reinstatement of respondent’s appeal (i.e., in admitting her belated Verification and Certificate of Non-Forum Shopping)?
- Was the termination of respondent’s employment justified as redundancy, or was petitioner in bad faith in declaring her position redundant?
- Does the Quitclaim signed by respondent bar her from pursuin...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)