G.R. No. 214961 - Banco De Oro Unibank, Inc. vs. Sagaysay

Nature of the Case: Petition for review on certiorari.
Parties Involved:
- Petitioner: Banco De Oro Unibank, Inc. (BDO)
- Respondent: Guillermo C. Sagaysay
Court: Supreme Court of the Philippines, Second Division
Decisions Reviewed:
- Court of Appeals Decision (March 31, 2014)
- Court of Appeals Resolution (October 8, 2014)
- National Labor Relations Commission (NLRC) Decision (February 29, 2012)
- Labor Arbiter (LA) Decision (July 19, 2011)

Employment History: Sagaysay was hired by BDO on May 16, 2006, post-merger with United Overseas Bank (UOB).
Retirement Notification: Sagaysay was formally notified of his retirement effective September 1, 2010, upon reaching age 60, as per BDO’s retirement policy.
Quitclaim Execution: Signed a Release, Waiver, and Quitclaim on October 22, 2010, in exchange for P98,376.14.
Complaint Filed: Sagaysay filed for illegal dismissal on January 10, 2011.

Legal Principle: Retirement is a voluntary agreement between employer and employee. The Labor Code allows employers to establish retirement plans.
Key Definitions:
- Compulsory Retirement Age: 60 years, as mandated by BDO's retirement plan.
- Optional Retirement: Age 50 with at least 10 years of service.
Requirements:
- Employees must be informed of the retirement plan and must have agreed to its terms.
Consequences:
- Unauthorized retirement can be classified as illegal dismissal.

Legal Principle: A quitclaim is generally valid if it is executed voluntarily with understanding of its implications.
Key Definitions:
- Quitclaim: A legal document where the employee relinquishes claims against the employer.
Requirements:
- Must be signed with full knowledge of the rights being waived.
- Must involve reasonable and credible consideration.
Consequences:
- A valid quitclaim can bar subsequent claims related to employment if it reflects a clear understanding of the employee's rights.

Ruling: Sagaysay was illegally dismissed, as he did not freely assent to the retirement plan.
Compensation Ordered: Reinstatement to former position, back wages, and damages awarded.

Ruling: Reversed LA decision, stating Sagaysay consented to the retirement plan by accepting employment.
Key Findings:
- BDO’s retirement plan was established prior to Sagaysay’s employment.
- Execution of quitclaim indicated acceptance of terms.

Ruling: Reversed NLRC decision, reinstating LA ruling.
Key Findings:
- Retirement plan was not mutually agreed upon, violating employee's rights.
- Quitclaim was deemed ineffective as Sagaysay had shown intent to retain employment.

Decision: Petition granted; the NLRC decision reinstated.
Key Findings:
- Sagaysay was informed and had impliedly consented to the retirement policy prior to employment.
- Quitclaim was valid and enforced based on his voluntary acceptance.

The Supreme Court upheld the validity of the BDO retirement plan, emphasizing the necessity for voluntary assent from employees.
A quitclaim, when executed with understanding and reasonable consideration, can effectively waive future claims against the employer.
This case reinforces the principle that retirement policies must be clearly communicated and agreed upon to be enforceable, while also highlighting the balance between employer prerogatives and employee righ