Case Digest (G.R. No. 107693)
Facts:
San Miguel Corporation v. National Labor Relations Commission, Edmundo Y. Torres, Jr. and Manuel C. Castellano, G.R. No. 107693, July 23, 1998, Supreme Court Third Division, Purisima, J., writing for the Court.Petitioner San Miguel Corporation operated the Bacolod Beer Region where private respondents — Edmundo Y. Torres, Jr., Manuel C. Castellano, and three other supervisory employees (Gabriel Adad, George D. Teddy, Jr., and Manuel G. Chu) — worked as members of the sales and supervisory force. In March 1984 petitioner informed these employees that effective April 15, 1984 it would exercise its option to retire them, and the employees were presented options framed as retirement, retrenchment, or dismissal. Respondents alleged they were not yet at compulsory retirement age and protested that the termination violated their security of tenure under the Labor Code; they also claimed coercion, intimidation (including an allegation that Personnel Director Antonio Labirua blocked a door and threatened them), and unequal separation pay treatment.
Petitioner maintained that four of the five (Adad, Castellano, Teddy and Torres) had applied for voluntary retrenchment/retirement and that all five were paid retirement/termination benefits (including retirement pay, financial assistance, unused leave pay and pro rata 13th month pay) and executed Releases and Receipts on April 16, 1984. Petitioner also asserted that Manuel Chu was retired pursuant to its Retirement and Death Benefit Plan and that the 1981 Collective Bargaining Agreement (CBA) reduced the service requirement for optional retirement from 20 to 15 years.
Labor Arbiter Oscar S. Uy (Regional Arbitration Branch No. VI, Bacolod City) found on September 16, 1988 that the complainants were not illegally dismissed, that their retirement/termination was voluntary, and dismissed the complaints. The complainants appealed to the Fourth Division of the National Labor Relations Commission (NLRC) in Cebu City. In its August 21, 1992 Decision (NLRC, Fourth Division; Comm. Irenea E. Ceniza, ponente; Pres. Comm. Ernesto G. Ladrido III, dissenting; Comm. Bernabe S. Batuhan, concurring), the NLRC set aside the Labor Arbiter and declared Adad, Teddy and Chu to have been validly retired, but ordered the reinstatement of Manuel C. Castellano and Edmundo Y. Torres, Jr., with payment of specified back salaries after deducting amounts they had already received as retirement pay. The NLRC denied petitioner's motion for reconsideration by Resolution dated October 19, 1992.
Petitioner brought a petition for certiorari under Rule 65 of the Revised Rules of Court to the Supreme Court, assigning errors that (1) respondents voluntarily chose retirement/retrenchment/dismissal (invoking Samaniego v. NLRC), (2) respondents’ receipt-and-release constituted a va...(Subscriber-Only)
Issues:
- Did the NLRC commit grave abuse of discretion warranting relief under Rule 65?
- Was the separation of private respondents voluntary retirement or an involuntary dismissal/constructive dismissal?
- Did the Receipts and Releases executed by respondents constitute valid and binding compromises that estopped them from contesting the legality of their separation?
- Did Section 2, Article XV of the 1981 Collective Bargaining Agreement (reducing retirable service to 15 years) a...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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