Case Summary (G.R. No. L-48757)
Background of the Case
The respondents, employed as a warehouse purchaser and welders, were issued termination notices in 2011 on the grounds of retirement before reaching the compulsory retirement age. They claimed illegal dismissal, contending that their termination was not consensual. An initial complaint was filed with the Department of Labor and Employment (DOLE), leading to a compromise agreement for separation pay, which the petitioner failed to honor. As a result, the matter escalated to the NLRC, where the labor arbiter ruled in favor of the respondents, declaring the dismissals illegal and ordering reinstatement and monetary awards.
NLRC Ruling and Compromise Agreement
The NLRC affirmed the labor arbiter’s decision, recalculating the total monetary compensation due to the respondents. Subsequently, the respondents sought to enforce the NLRC ruling demanding reinstatement and full backwages. The petitioner paid a portion of the monetary award and requested closure of the case upon the respondents’ execution of quitclaims and releases, signifying the settlement of claims.
Rejection of Quitclaim Execution
Respondents later contested the validity of the quitclaims, arguing that they were not adequately advised by counsel during execution and were misled into believing reinstatement would follow the quitclaims. In contrast, the petitioner asserted that the quitclaims were executed knowingly and that all wage obligations had been satisfied. The NLRC ultimately upheld the quitclaims, discharging the petitioner from its obligations.
Court of Appeals Intervention
The Court of Appeals granted the respondents' petition for certiorari, setting aside the NLRC’s ruling. The CA found the quitclaims did not bar respondents from additional claims for backwages, as they did not sign away their right to reinstatement or a full monetary judgment. The CA reiterated that labor agreements cannot deprive employees of the full compensation they are legally entitled to receive.
Supreme Court's Analysis
The Supreme Court upheld the CA's decision, finding that the quitclaims did not extinguish the petitioner’s obligation for reinstatement, merely settling the monetary aspect related to backwages. The Court clarified
...continue readingCase Syllabus (G.R. No. L-48757)
Case Background
- The petition for review on certiorari stems from the Decision dated February 8, 2017, and the Resolution dated January 4, 2018, of the Court of Appeals (CA) in CA-G.R. SP. No. 08468.
- The CA reversed and set aside the Order dated April 30, 2013, and the Resolution dated March 31, 2014, of the National Labor Relations Commission (NLRC) in NLRC Case No. VAC-03-000204-2012.
- The ruling mandated the remand of the case to the NLRC for the re-computation of the award of backwages until the respondents' reinstatement or, if not viable, for the payment of separation pay.
Employment and Termination
- Respondents Jose B. Galandez, Domingo I. Sajuela, and Marlon D. Namoc were employed by petitioner F.F. Cruz & Co., Inc. as warehouseman, purchaser, and welder, respectively.
- In April and May 2011, the respondents received notices of termination citing retirement as the reason.
- The respondents argued that their termination was illegal as they had not yet reached the compulsory retirement age and were compelled to retire without their consent.
Initial Complaints and Settlement Attempts
- The respondents filed a complaint with the Department of Labor and Employment (DOLE) alleging illegal dismissal.
- During conciliation, the petitioner proposed a compromise to pay separation pay equivalent to one month for each year of service.
- However, the petitioner failed to fulfill this agreement, leading to the referral of the matter to the NLRC.
NLRC Proceedings
- The Labor Arbiter ruled in favor of the respondents on December 15, 2011, declaring their termination illegal and ordering their reinstatement without loss of seniority rights.
- The NLRC affirmed this decision on Jul