Title
Zambrano vs. Philippine Carpet Manufacturing Corp.
Case
G.R. No. 224099
Decision Date
Jun 21, 2017
The Court upheld the legality of the employees' termination due to the company's closure and validated the quitclaims signed by the employees.
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Case Digest (G.R. No. 224099)

Facts:

  • Rommel M. Zambrano and 40 other employees of Philippine Carpet Manufacturing Corporation (Phil Carpet) filed a petition for review on certiorari.
  • The employees received termination notices effective February 3, 2011, citing cessation of operations due to serious business losses.
  • Petitioners claimed their dismissal was unjust and violated due process, alleging the closure was a pretext to transfer operations to a subsidiary, Pacific Carpet Manufacturing Corporation.
  • They asserted that job orders were shifted to Pacific Carpet and machinery was moved between October and November 2011.
  • Phil Carpet defended itself by stating it suffered continuous financial losses, supported by audited financial statements, and complied with Labor Code requirements for business closure.
  • The Labor Arbiter dismissed the complaints for illegal dismissal and unfair labor practice, ruling the termination was justified due to economic necessity.
  • The National Labor Relations Commission (NLRC) affirmed this decision, and the Court of Appeals (CA) upheld the ruling as well.
  • A motion for reconsideration by the petitioners was denied, leading to the current petition.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that:
    • The petitioners were terminated for a lawful cause.
    • Their termination did not constitute unfair labor practice.
    • Pacific Carpet could not be held liable for Phil Carpet's obli...(Unlock)

Ratio:

  • The Court determined that the termination was justified under Article 298 of the Labor Code, which permits termination due to authorized causes like serious business losses.
  • Evidence, including audited financial statements, showed Phil Carpet incurred significant losses over several years, justifying the closure.
  • The Court emphasized that the closure was genuine and not intended to ev...continue reading

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