Case Digest (G.R. No. 208027)
Facts:
Philippine Journalists Inc. v. Erika Marie R. De Guzman and Edna Quirante, G.R. No. 208027, March 23, 2020, Supreme Court First Division, Del Castillo, J., writing for the Court.Petitioners are Philippine Journalists, Inc. (PJI) and several corporate officers; respondents are employees Erika Marie R. De Guzman and Edna Quirante. De Guzman worked for PJI from May 11, 1994 until November 15, 2008 as an Ad Taker/Account Executive (and, it was found, Executive Security to the Chairman); Quirante was employed since September 5, 1989 and ceased employment on March 15, 2009 as HRD Supervisor. Both tendered letters (October 28, 2008 and January 23, 2009) expressing their desire to avail themselves of PJI’s optional retirement plan as set out in the Collective Bargaining Agreement (CBA).
Respondents filed complaints for unfair labor practice and money claims for nonpayment of optional retirement benefits when PJI failed or refused to process their applications. The Labor Arbiter dismissed the complaints on April 29, 2010, holding that the CBA excluded certain managerial positions (listed in Annex A) from coverage and that respondents were not rank-and-file employees entitled to the optional retirement benefit.
Respondents appealed to the National Labor Relations Commission (NLRC). In a December 29, 2011 Decision, the NLRC reversed the Labor Arbiter, finding that (1) the CBA’s Article XIV provides for optional retirement, (2) PJI had previously granted optional retirement benefits to managerial/confidential employees in practice, and (3) such past voluntary grants had ripened into a company practice enforceable against PJI; the NLRC ordered payment of the benefits.
Petitioners filed a Petition for Certiorari with the Court of Appeals (CA) in CA-G.R. SP No. 123901. On November 7, 2012, the CA denied the petition and affirmed the NLRC, concluding that although respondents were excluded from the CBA’s bargaining unit, PJI’s prior voluntary grants of optional retirement benefits to non–rank-and-file employees had ripened into an enforceable company practice; the CA denied reconsideration on July 4, 2013.
Petitioners then filed a Petition for Review on Cer...(Subscriber-Only)
Issues:
- What is the distinction between compulsory retirement and optional retirement?
- Whether an optional retirement benefit can be demanded as a mandatory benefit by a regular employee who voluntarily resigns even without an approved optional retirement prog...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)