Case Digest (G.R. No. 5751) Core Legal Reasoning Model
Facts:
In Guido B. Pulong v. Super Manufacturing Inc., Engr. Eduardo Dy, and Ermilo Pico (G.R. No. 247819, decided February 8, 2021), the petitioner, Guido B. Pulong, filed a complaint for illegal dismissal, non-payment of wages, 13th month pay, damages, and attorney’s fees against respondent Super Manufacturing Inc. (SMI) and individuals Engr. Eduardo Dy and Ermilo Pico. Pulong was originally hired as a spot welder in December 1978 by SMI's Quezon City production plant. After receiving separation pay in 1998 due to the plant’s transfer, he was re-employed on August 1, 1998, as Senior Die Setter at SMI’s Laguna plant and continuously worked until denied entry on September 22, 2014. SMI’s Personnel Manager Ermilo Pico presented him a document declaring compulsory retirement at age 60 pursuant to a Memorandum of Agreement (MOA) dated January 1, 2013 between SMI and purported workers’ representatives, asserting that Pulong was compulsorily retired due to reaching age 60. Pulong refus
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Case Digest (G.R. No. 5751) Expanded Legal Reasoning Model
Facts:
- Background and Employment History
- Petitioner Guido B. Pulong was hired by respondent Super Manufacturing Inc. (SMI) in December 1978 as a spot welder at its Quezon City plant.
- In May 1998, following SMI’s transfer of production to Calamba City, Laguna, petitioner and other workers received separation pay.
- Petitioner was re-employed on August 1, 1998 as a Senior Die Setter and continued working for SMI until 2014.
- Circumstances Leading to Dispute
- On September 22, 2014, petitioner was denied entry into SMI’s plant by Personnel Manager Ermilo Pico, who presented a document indicating petitioner was compulsorily retired upon reaching age 60.
- Petitioner refused to sign retirement papers, expressing his desire to work until age 65, but SMI prevented his return.
- Respondents’ Defense and MOA
- Respondents justified the compulsory retirement citing a Memorandum of Agreement (MOA) dated January 1, 2013 between SMI and workers’ representatives (Eduardo K. Abad, Glenn B. Bionat, Julio D. Cruz).
- The MOA provided for:
- Retirement age at 60 years with at least five years continuous service;
- Optional retirement at 20 years continuous service;
- Retirement pay in accordance with the law.
- Petitioner’s Counterarguments
- Petitioner asserted he was not a party to the MOA as he did not sign it, and that the supposed workers’ representatives lacked authority to bind him and others.
- An affidavit from thirteen other SMI workers denied authorizing the MOA signatories or being aware of the MOA and its retirement provisions.
- Labor Arbiter’s Decision
- Labor Arbiter ruled petitioner was illegally dismissed due to failure of respondents to prove the MOA’s binding effect and authenticity of workers’ representatives.
- Ordered reinstatement without loss of seniority and payment of backwages amounting to PHP 125,815.03, plus attorney’s fees.
- NLRC Proceedings
- Initially affirmed the Labor Arbiter’s decision on September 30, 2015, finding lack of proof on the authorization of MOA signatories.
- Upon respondents’ motion and submission of documentary proofs of benefits availed under the MOA (uniforms, Christmas gift, leave credits monetization, health cards), the NLRC issued a February 29, 2016 resolution:
- Ruled petitioner and co-workers were estopped from assailing MOA validity due to acceptance of benefits;
- Found the MOA binding and ordered dismissal of illegal dismissal complaint;
- Directed payment of retirement benefits amounting to PHP 211,200.00.
- Denied petitioner’s motion for reconsideration while modifying retirement pay to PHP 216,000.00 under DOLE Advisory and jurisprudence.
- Court of Appeals Ruling
- On July 13, 2018, the CA affirmed the NLRC’s ruling upholding compulsory retirement at age 60 under the MOA signed by authorized workers’ representatives.
- Denied petitioner’s motion for reconsideration on March 6, 2019.
- Present Petition before the Supreme Court
- Petitioner sought to nullify appellants’ rulings, contending the retirement was illegal since he did not consent and only accepted benefits as gratuities.
- Respondents maintained the MOA’s binding nature due to petitioner’s receipt of benefits and its execution by authorized representatives.
Issues:
- Whether the Court of Appeals erred in upholding petitioner’s compulsory retirement at age 60 under the MOA dated January 1, 2013.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)