Case Summary (G.R. No. 238762)
Employment History and Retirement Notice
Raul Cipriano was initially employed by San Miguel Corporation as an apprentice salesman on September 1, 1953, with a starting salary of P215. He progressed to a regular salesman by March 1, 1954, receiving a monthly salary of P240. Over the course of his employment, his salary experienced several increments, reaching P290 by January 1, 1963, with additional average monthly commissions of P367.11. On April 21, 1964, Cipriano was notified that he could no longer perform his job due to medical reasons, leading to his retirement effective April 17, 1964.
Retirement Benefits
Cipriano was a member of the San Miguel Brewery Sales Force Union, which had a Health, Welfare, and Retirement Plan in place since February 20, 1963. According to Section 2 of Article VIII of this plan, retiring employees were entitled to benefits calculated as one month's guaranteed basic compensation for each year of service. Cipriano received a total of P2,292.28 in retirement benefits based on his years of service.
Legal Claims and Court Proceedings
Subsequent to receiving his retirement benefits, Cipriano filed a claim for separation pay in accordance with Republic Act No. 1052, as amended by Republic Act No. 1787, citing the Termination Pay Law. When San Miguel Corporation did not comply with his demand, he initiated legal proceedings on December 1, 1964, seeking to recover separation pay, as well as moral damages, exemplary damages, and attorney's fees.
Court Decision and Reasoning
The Court of First Instance dismissed Cipriano's complaint, concluding that the retirement benefits he received under the Health, Welfare, and Retirement Plan were in lieu of the termination pay he sought. The court emphasized that Cipriano's entitlement to benefits was governed by the terms of the collective agreement which stated that employees separated for reasons other than misconduct or voluntary resignation would receive either the retirement benefits or the severance pay provided by law, whichever amount was greater.
Interpretation of Employment Agreement
The court interpreted the agreement's language strictly, highlighting that the use of "either" and "or" indicated that Cipriano was only entitled to one form of benefit, not both simultaneously. The phrase "whichever is the greater amount" further substantiated t
...continue readingCase Syllabus (G.R. No. 238762)
Case Background
- The case involves a direct appeal regarding questions of law from the Court of First Instance of Manila.
- The plaintiff-appellant, Raul Cipriano, contested a dismissal of his complaint against the defendant-appellee, San Miguel Corporation.
- The dismissal was issued without costs.
Employment History
- Raul Cipriano began his employment with San Miguel Corporation on September 1, 1953, as an apprentice salesman with a monthly salary of P215.
- On March 1, 1954, he transitioned to a regular salesman with an increased salary of P240.
- Throughout his employment, Cipriano received regular promotions, culminating in a salary of P290 as of January 1, 1963.
- From January 1, 1963, until April 17, 1964, he earned an average monthly commission of P367.11.
Retirement Notification
- On April 21, 1964, Cipriano received notification that he could no longer perform his duties as a salesman due to a medical assessment.
- He was informed that he would be retired at the close of business on April 17, 1964.
Union Membership and Retirement Plan
- At the time of his retirement, Cipriano was an active member of the San Miguel Brewery Sales Force Union.
- The union had established a "Health, Welfare and Retirement Plan"