Case Digest (G.R. No. L-7756) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1951, respondents Crispin Jeturian and about sixty fellow prewar employees filed in the Court of Industrial Relations (Case No. 639-V) a petition against the Philippine Long Distance Telephone Company (PLDT) claiming (1) pension benefits under a “Plan for Employees’ Pensions” established on September 18, 1923 by PLDT’s predecessor, the Philippine Telephone and Telegraph Company, and later adopted by PLDT, and (2) salary arrears from January 1946. Under the pension plan, male employees of “brown skinned race” aged 50 with at least 20 years’ service—and female employees aged 45 with at least 20 years—could, at their own request or at directors’ discretion, retire and receive a pension equal to 1½ percent of their average annual pay during the last five years of service for each year served. Section 5 conditioned vesting on age and service, prohibited assignment, allowed suspension for misconduct, treated unexcused absences as breaks in service, and defined temporary lay-offs. B Case Digest (G.R. No. L-7756) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proceedings
- In 1951, Crispin Jeturian and about sixty co-employees (respondents) filed Petition No. 639-V in the Court of Industrial Relations against Philippine Long Distance Telephone Company (PLDT) seeking:
- Monetary benefits under the “Plan for Employees’ Pensions” established September 18, 1923 by the predecessor Philippine Telephone and Telegraph Co. and later adopted by PLDT.
- Unpaid salaries from January 1946.
- PLDT moved to dismiss on the ground that World War II terminated employer–employee relations; motion denied. PLDT’s certiorari petition (G.R. L-5697) was dismissed by the Supreme Court on June 10, 1952.
- Pension Plan and War Events
- The 1923 plan provided that male employees aged 50 (female 45) with ≥20 years’ service could retire and receive 1.5% of average annual pay for each year of service as pension, subject to directors’ discretion and conditions on assignment, suspension for misconduct, and service continuity.
- By October 31, 1941, a “Provident Reserve” of ~₱221,074.14 existed. On November 6, 1945, PLDT’s board retroactively discontinued the plan effective January 1, 1942, citing lack of jurisdictional operations and revenue during the war.
- During the Japanese occupation, management urged employees to remain; they worked under occupation administration but were not recalled when PLDT resumed postwar operations in 1946.
- Court of Industrial Relations Decision
- The CIR held the pension plan was a binding contract, not a mere gratuity, and that the war only suspended, not terminated, employment relations.
- Equity required liquidation: prewar employees were to receive proportionate pension benefits based on age and length of service as of October 31, 1941, and one month’s severance pay for non-recalled employees, excluding those who died, obtained other employment, or refused reinstatement.
Issues:
- Whether the 1923 pension plan constituted a binding contractual obligation or a revocable gratuity.
- The legal effect of PLDT’s retroactive discontinuance of the plan as of January 1, 1942, and of World War II on employer–employee relations and on the employees’ pension rights.
- The appropriate remedy and measure of damages for prewar employees who were not reinstated postwar.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)