Case Digest (G.R. No. 205278)
Facts:
Philippine Spring Water Resources, Inc. / Danilo Y. Lua, Petitioners, G.R. No. 205278, June 11, 2014, Supreme Court Third Division, Mendoza, J., writing for the Court. Petitioner Philippine Spring Water Resources, Inc. (PSWRI) hired Juvenstein B. Mahilum in June 2004 as Vice-President for Sales and Marketing (Bulacan–South Luzon), with a monthly salary of P15,000 and two 0.25% commissions on certain collections and new accounts. In November–December 2004 he was designated overall chairman for the Bulacan plant inauguration/Christmas party but missed several preparatory meetings and was not present to supervise parts of the program; he said he had delegated duties to Ms. Vicky Evangelista.After the affair, PSWRI’s president Danilo Y. Lua complained that Mahilum was not properly recognized and Mahilum was placed under a 30‑day preventive suspension and later terminated by memorandum dated January 31, 2005 (effective February 1, 2005). Mahilum received P43,998.56 and executed a Release, Waiver and Quitclaim; he later filed for illegal dismissal seeking reinstatement, backwages and damages, alleging constructive dismissal and coercion to sign the quitclaim.
The Labor Arbiter dismissed Mahilum’s complaint on April 25, 2006, finding the quitclaim voluntarily executed and estopping him from contesting termination. Mahilum appealed and on October 11, 2006 the National Labor Relations Commission (NLRC) reversed, ruling the quitclaim did not bar the illegal dismissal action and declaring the dismissal illegal, awarding backwages, separation pay and moral and exemplary damages. PSWRI’s motion for reconsideration was denied and it sought relief from the Court of Appeals (CA).
On September 30, 2008, the CA (Twentieth Division) reversed the NLRC: it held the quitclaim valid and barred Mahilum’s recovery, although it also found the termination illegal on the merits. Mahilum filed for reconsideration, and on July 23, 2010 the CA issued an Amended Decision (Twentieth Division) reinstating NLRC’s result — declaring dismissal illegal, holding the quitclaim void for lack of consideration, and awarding full backwages and separation pay; a motion for reconsidera...(Pro-only)
Issues:
- Was the petition properly brought under Rule 65, or was Rule 45 the proper remedy?
- Was Mahilum a regular employee entitled to security of tenure or still a probationary/contractual employee?
- Was Mahilum illegally dismissed for causes recognized in the Labor Code?
- Are the 0.25% commissions part of Mahilum’s backwages?
- Were awards of moral and exemplary damages proper, and is Mahil...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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