Case Summary (G.R. No. 227797)
Background of the Case
Del Rio submitted his resignation on September 7, 2009, which came into effect on October 7, 2009. Following the resignation, he realized he was owed unpaid salaries for the period between September 16, 2009, and October 7, 2009, as well as accrued leave credits and separation pay. Despite requests for these unpaid amounts, DPO denied his claims, citing a violation of the non-competition clause in his contract, as Del Rio had registered his own competing business shortly before his resignation.
Proceedings in Lower Courts
Del Rio filed a complaint with the National Labor Relations Commission (NLRC) on October 9, 2009, seeking recovery of his claims. The labor arbiter ruled in favor of Del Rio, awarding him the unpaid salaries, benefits, and separation pay amounting to PHP 520,192.75. DPO appealed to the NLRC, which affirmed the labor arbiter's decision without modifications.
Subsequently, DPO filed a petition for certiorari in the Court of Appeals (CA), arguing that Del Rio's voluntary resignation disqualified him from receiving separation pay. They contended that there was no established company practice or policy providing separation pay to employees who resigned voluntarily and highlighted that previous instances of separation pay awarded to other employees were due to unique circumstances.
Ruling of the Court of Appeals
On November 6, 2013, the CA modified the NLRC’s decision by deleting the separation pay awarded to Del Rio. The court held that an employee who voluntarily resigns is generally not entitled to separation pay unless such entitlement is expressly stated in an employment contract, a collective bargaining agreement, or is based on an established company practice. The CA ruled that none of these circumstances applied to Del Rio, as there was no supporting evidence of a company policy or contract provision that allowed for separation pay in the event of voluntary resignation.
Petition to the Supreme Court
Del Rio filed a motion for reconsideration, which was rejected by the CA on February 7, 2014, leading to a petition for review on certiorari to the Supreme Court. The key issue presented was whether the CA erred in deleting the award of separation pay.
Supreme Court's Analysis and Ruling
The Supreme Court reviewed and affirmed the findings of the CA, noting that the arguments presented by DPO against the awarding of separation pay were valid and had been properly raised during the initial proceedings. The Court reiterated the legal principle that employees who voluntarily resign are typically not entitled to separation pay unless expressly provided for in their employment contract or supported by a consistent company policy.
The Court also examined the cla
...continue readingCase Syllabus (G.R. No. 227797)
Case Background
- The case involves a petition for review on certiorari filed by Jude Darry A. Del Rio against DPO Philippines, Inc. and its officials, Daniel Pans and Grace Lucero.
- The petition challenges the Decision dated November 6, 2013, and the Resolution dated February 7, 2014, of the Court of Appeals-Cebu City.
- These decisions modified the earlier ruling of the National Labor Relations Commission (NLRC) which granted Del Rio separation pay.
Facts of the Case
- Jude Darry A. Del Rio was employed as the Assistant Country Manager for DPO Philippines, Inc., a Belgian multi-national food distribution company.
- He successfully established the company's operations in Cebu and later in Davao.
- On September 7, 2009, Del Rio submitted his resignation, effective October 7, 2009, which was accepted by DPO.
- DPO published a notice confirming his resignation.
- Upon resignation, Del Rio claimed he was not paid his salary from September 16 to October 7, 2009, and sought payment for unpaid salaries, accrued leave credits, and separation pay, which DPO denied.
- DPO later discovered that Del Rio had registered a competing business, Judphilan Foods, shortly before his resignation.
- Despite offering Del Rio a settlement of P110,692.75 for his unpaid salaries and commissions,