Case Summary (G.R. No. 213486)
Employment History and Retirement Policy
Editha Catotocan commenced her employment with Lourdes School in 1971, eventually serving for thirty-five years as a music teacher. The school’s retirement policy enables employees to retire upon reaching sixty years of age or after thirty years of service, whichever comes first. Catotocan raised objections to aspects of this policy, particularly its provision stipulating an earlier retirement age based on years of service.
Requests and School Response
In March 2004, Catotocan, together with several colleagues, formally requested the deferment of the new retirement provision set forth in Administrative Order No. 2003-004. Their appeal sought to allow for retirement at the age of sixty instead of after thirty years of service. The school's leadership maintained that the retirement age reflected similar policies in other educational institutions and advised patience due to an ongoing related case.
Interaction with Labor Authorities and Subsequent Developments
After multiple communications with school officials, Catotocan sought intervention from the Department of Labor and Employment-National Capital Region. Notably, Atty. Jose Mari Villaflor emphasized that mandatory retirement could resemble constructive dismissal if not appropriately addressed.
Retirement Notification and Benefits
In January 2005, Catotocan was advised that she would be retired by the end of the school year, after serving thirty years, with calculated retirement benefits amounting to over one million Philippine pesos. Following her "retirement," Catotocan initially expressed dissatisfaction but later engaged in activities consistent with acceptance of her status as a retiree, including opening a savings account linked to her retirement proceeds.
Contractual Employment After Retirement
Upon her retirement in June 2006, Catotocan was offered a rehired position under a contractual arrangement as a Grade School Guidance Counselor. Over the following years, she continued to apply for and accept appointments in this role, receiving compensation throughout.
Labor Complaint and Initial Rulings
In June 2009, Catotocan filed for illegal dismissal, alleging her retirement was effectively forced. The Labor Arbiter dismissed her complaint, citing that her actions indicated acquiescence to the retirement policy. This decision was upheld by the National Labor Relations Commission, which recognized her voluntary acceptance of retirement benefits and her subsequent contractual employment actions.
Court of Appeals’ Decision
Catotocan sought certiorari before the Court of Appeals, which ultimately affirmed the prior rulings, concluding that the respondent did not illegally dismiss her and that her actions post-retirement implied consent to the school’s retirement policy.
Legal Principles and Conclusions
The Supreme Court upheld the decisions made by the lower courts, emphasizing that retirement is a bilateral act dependent on mutual agreement. The r
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Case Background
- This case arises from a Petition for Review on Certiorari under Rule 45 of the Rules of Court, filed by Editha M. Catotocan against Lourdes School of Quezon City, Inc. and Rev. Fr. Cesar F. Acuin, OFM CAP.
- The petition seeks to reverse the Decision dated October 29, 2013, and Resolution dated July 15, 2014, of the Court of Appeals, which dismissed Catotocan’s Petition for Certiorari under Rule 65 of the 1997 Rules of Civil Procedure.
- The earlier decisions of the National Labor Relations Commission (NLRC) dated October 20, 2010, and May 13, 2011, which ruled against Catotocan’s claims, were affirmed by the Court of Appeals.
Employment History
- Editha Catotocan began her employment at Lourdes School of Quezon City (LSQC) in 1971 as a music teacher, with a monthly salary of Php 30,081.00.
- By the school year 2005-2006, she had completed thirty-five years of service.
- LSQC had a retirement plan that allowed retirement at age 60 or after 30 years of service, whichever came first, as outlined in Administrative Order No. 2003-004 issued on November 25, 2003.
Appeals Against Retirement Policy
- On March 23, 2004, Catotocan and seven co-employees appealed to the Provincial Minister of LSQC, requesting the deferment of the retirement policy that mandated retirement after 30 years of service.
- They argued for an option to retire at age 60 to fully enjoy their labor’s benefits.
- LSQC responded on April 25, 2004, maintaining that the retirement age was in line with other schools’ policies.
Retirement Notification and Acceptance
- On January 27, 2005, LSQC notified Catotocan that she would be retired at the end of the school year due to her t