Case Summary (G.R. No. 214961)

Background of the Case

• The case involves a petition for review on certiorari by Banco De Oro Unibank, Inc. (BDO) against Guillermo C. Sagaysay.
• The petition seeks to reverse the Court of Appeals' decision that reinstated the Labor Arbiter's ruling declaring Sagaysay's retirement as illegal.
• Sagaysay was employed by BDO as a Senior Accounting Assistant after a merger with United Overseas Bank (UOB) and was informed of his compulsory retirement at age sixty.

Employment and Retirement Policy

• Sagaysay was hired on May 16, 2006, and had a long banking career prior to his employment with BDO.
• BDO's retirement policy mandated retirement at age sixty, established in a retirement plan effective since July 1, 1994.
• Sagaysay requested an extension of his service due to financial obligations, which BDO denied, leading to his retirement on September 1, 2010.

Legal Proceedings Initiated by Sagaysay

• Following his retirement, Sagaysay signed a quitclaim for a settlement amount but later filed a complaint for illegal dismissal, claiming damages for being forced into retirement.
• BDO contended that Sagaysay was not dismissed but retired in accordance with the bank's policy.

Labor Arbiter's Decision

• The Labor Arbiter ruled in favor of Sagaysay, declaring his retirement illegal and ordering BDO to reinstate him with back wages and damages.
• The ruling was based on the assertion that Sagaysay did not freely assent to the retirement plan.

National Labor Relations Commission (NLRC) Ruling

• The NLRC reversed the Labor Arbiter's decision, stating that Sagaysay had assented to the retirement plan when he accepted employment with BDO.
• The NLRC emphasized that Sagaysay's execution of the quitclaim indicated his acceptance of the retirement policy.

Court of Appeals (CA) Ruling

• The CA reversed the NLRC ruling, stating that the retirement plan was not mutually agreed upon and that Sagaysay was compelled to participate.
• The CA found that the quitclaim was not credible due to Sagaysay's subsequent actions indicating he did not intend to relinquish his employment.

Issues Presented

• The primary issues were the validity of the retirement plan and the legitimacy of the quitclaim signed by Sagaysay.
• BDO argued that the retirement plan was valid and recognized in the collective bargaining agreement, while Sagaysay contended he was retired against his will.

Court's Ruling on Retirement Plan Validity

• The Court found the retirement plan valid, emphasizing that retirement is a bilateral agreement and that Sagaysay had consented to the plan upon employment.
• The Court noted that the retirement plan was established before Sagaysay's employment, making it binding.

Court's Ruling on Quitclaim Validity

• The Court upheld the validity of the quitclaim, stating that Sagaysay, being an experienced banker, understood the implications of signin...continue reading

Case Syllabus (G.R. No. 214961)

Case Overview

• This case involves a petition for review on certiorari by Banco De Oro Unibank, Inc. (BDO) seeking to reverse the decisions of the Court of Appeals (CA) which reinstated the ruling of the Labor Arbiter (LA) declaring Guillermo Sagaysay's retirement as illegal.
• The case number is G.R. No. 214961 and the ruling was made on September 16, 2015.

Background of the Case

• Guillermo Sagaysay was hired by BDO on May 16, 2006, as a Senior Accounting Assistant 5 following BDO's merger with United Overseas Bank (UOB).
• Prior to this, Sagaysay had a long banking career, including two years at UOB and thirty-eight years at Metrobank.

Retirement Notification

• On January 8, 2010, BDO informed Sagaysay via letter that he would be retired effective September 1, 2010, as per the bank's retirement policy that set the retirement age at sixty (60).
• Sagaysay requested an extension of his services due to personal financial issues but BDO denied his requests.

Quitclaim Execution

• Sagaysay signed a Release, Waiver, and Quitclaim on October 22, 2010, in exchange for P98,376.14, which stated he released BDO from any claims relating to his employment.

Legal Proceedings

• In January 2011, Sagaysay filed a complaint for illegal dismissal against BDO, claiming he was forced in...continue reading