Case Digest (G.R. No. 164774)
Facts:
Star Paper Corporation, Josephine Ongsitco & Sebastian Chua v. Ronaldo D. Simbol, Wilfreda N. Comia & Lorna E. Estrella, G.R. No. 164774, April 12, 2006, Supreme Court Second Division, Puno, J., writing for the Court.Petitioners are Star Paper Corporation (the company), and its officers Josephine Ongsitco (Manager, Personnel and Administration) and Sebastian Chua (Managing Director). Respondents are employees Ronaldo D. Simbol, Wilfreda N. Comia, and Lorna E. Estrella, who each left employment after the company applied a no-relatives/no-spouse employment policy promulgated about 1995 that barred relatives up to the third degree from working in the same company.
Chronology and procedural history: Simbol (hired October 27, 1993) married a co-employee, Alma Dayrit, on June 27, 1998; Ongsitco allegedly informed the couple that under company policy one of them must resign, and Simbol resigned on June 20, 1998. Comia (hired February 5, 1997) married a co-worker on June 1, 2000 and resigned on June 30, 2000 after similar admonition. Estrella (hired July 29, 1994) became involved with a co-worker who turned out to be married; after an accident and a 21-day medical leave she returned December 21, 1999, was allegedly barred from entry, handed a memorandum terminating her for immoral conduct, refused to sign, submitted an explanation, and ultimately tendered a handwritten resignation in exchange for her thirteenth-month pay on account of urgent need for money.
The respondents signed Release and Confirmation Agreements but later filed complaints for unfair labor practice, constructive dismissal, separation pay and attorney’s fees alleging the company policy contravenes Article 136 of the Labor Code and that their resignations were compelled. On May 31, 2001 the Labor Arbiter dismissed the complaints, characterizing the policy as an exercise of management prerogative. The National Labor Relations Commission (NLRC) affirmed on January 11, 2002 and denied reconsideration on August 8, 2002. The Court of Appeals (CA) in CA‑G.R. SP No. 73477 reversed the NLRC on August 3, 2004, declaring the dismissals illegal and ordering reinstatement with full backwages and attorney’s fees. Petitioners brought a Petition for Review on Certiorari to the Suprem...(Subscriber-Only)
Issues:
- Does petitioners’ 1995 employment policy banning relatives (including spouses) from working in the same company violate the Constitution and Article 136 of the Labor Code, or is it a valid exercise of management prerogative?
- Were respondents’ departures from employment voluntary resignations, or were they compelled such that their dismissals were illega...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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