Case Summary (G.R. No. 200575)
Employment Background
Jeremias Cabiles joined Intel Phil. on April 16, 1997, as an Inventory Analyst and went through several promotions and assignments until he received an offer from Intel HK on December 12, 2006. Prior to accepting this offer, he sought clarification on his retirement benefits, specifically questioning if he would still be entitled to these benefits despite not having completed the required ten years of service.
Intel Phil.'s Response
In response to Cabiles' inquiry on January 23, 2007, Intel Phil. informed him that he would not qualify for retirement benefits since he had not yet reached the ten-year service mark. Cabiles accepted the job offer from Intel HK on January 31, 2007, indicating his acknowledgment of the conditions laid out by Intel Phil.
Resignation and Waiver
After accepting the position with Intel HK, Cabiles received a final pay package and signed a Release, Waiver, and Quitclaim acknowledging full settlement of all benefits due to him from Intel Phil. This waiver was later contested by Cabiles when he filed a complaint with the NLRC for retirement benefits, asserting that his total service should amount to over ten years when including his time at Intel HK.
Labor Arbiter’s Decision
The Labor Arbiter ruled in favor of Cabiles, declaring him eligible for retirement benefits, citing that relocation to Intel HK did not constitute a severance of employment. The Arbiter deemed that the Waiver signed by Cabiles only covered specific final payments and did not pertain to retirement benefits.
NLRC Ruling
Upon appeal, the NLRC modified the Labor Arbiter's ruling, holding Intel Phil. solely liable for Cabiles’ retirement benefits, finding theWaiver signed insufficient to preclude Cabiles' claim as retirement pay had not yet accrued at the time of his resignation.
Court of Appeals Decision
Intel Phil. sought relief through a petition for certiorari to the Court of Appeals, which ultimately dismissed the petition and upheld the NLRC's decision. Intel Phil.'s motion for reconsideration was also denied.
Petition for Review
The case was brought before the Supreme Court where Intel Phil. raised several issues, including claims of procedural error by the Court of Appeals, the NLRC's alleged abuse of discretion, and a demand for restitution of amounts previously paid to Cabiles under a writ of execution.
Supreme Court Ruling
The Supreme Court found that Cabiles had effectively resigned from Intel Phil. upon accepting the position with Intel HK, which constituted a severance of his existing employment relationship. The Court rejected the theory of secondment, concluding that Cabiles' transfer to Intel HK was not an assignment but a permanent tra
...continue readingCase Syllabus (G.R. No. 200575)
Case Background
- Parties Involved: Intel Technology Philippines, Inc. (Petitioner) and National Labor Relations Commission (NLRC) and Jeremias Cabiles (Respondents).
- Nature of Petition: Petition for review on certiorari under Rule 45 of the Rules of Court.
- Dates of Key Resolutions: The petition challenges the October 28, 2011, and February 3, 2012, Resolutions of the Court of Appeals (CA) affirming the NLRC's ruling.
- Initial NLRC Decision: The NLRC decision modified the Labor Arbiter's ruling, holding Intel Phil. solely liable for Cabiles' retirement benefits.
Facts of the Case
- Employment History: Cabiles was employed by Intel Phil. since April 16, 1997, and held various positions, including an expatriate assignment in Chengdu and a promotion to Finance Manager in Intel HK.
- Retirement Benefits Inquiry: Before accepting the position at Intel HK, Cabiles inquired via email about the implications for his retirement benefits concerning his service duration.
- Intel Phil.'s Response: The company informed Cabiles that he was not eligible for retirement benefits as he had not completed the ten-year service requirement at the point of his transfer to Intel HK.
- Separation and Claims: Cabiles signed a Final Pay Separation Voucher and a Release, Waiver and Quitclaim, acknowledging receipt of his final pay but later filed a complaint for non-payment of retirement benefits.
Labor Arbiter's Decision
- Ruling: The Labor Arbiter ordered Intel Phil. to pay Cabiles HKD 419,868.77 as retirement pay, reasoning that Cabiles did not sever his relationship with Intel Phil. upon moving to Intel HK.
- Significance of Waiver: The Labor