Case Summary (G.R. No. 182331)
Nature of the Case
The petitioners, consisting of regular employees of the Philippine Banking Corporation (Philbank), filed a Petition for Review on Certiorari to contest the Resolutions issued by the Court of Appeals (CA) regarding their claims for additional separation pay following their redundancy due to a merger.
Antecedent Facts
The petitioners had been employed by Philbank for at least a decade, and benefits were governed initially by the company's Old Gratuity Pay Plan dating back to 1970. Upon a merger with Global Business Bank, a new Gratuity Plan was introduced. In connection with the redundancy of their positions, the petitioners signed releases and waivers to receive separation packages under a Special Separation Program (SSP), which provided them 150% of their monthly salaries for every year served.
Petitioners' Claims
The petitioners asserted their entitlement to additional gratuity pay under both the Old and New Gratuity Plans, contending that they should receive a full payment corresponding to their years of service. They further claimed that the quitclaims they signed upon accepting the SSP should not bar them from seeking full benefits, alleging that they had been misled into signing the waivers without understanding their legal implications.
Respondents' Position
Globalbank argued that the SSP covered all separation benefits owed to the petitioners, rendering them ineligible for any additional gratuity pay. They maintained that the quitclaims executed by the petitioners were binding as these were made freely and with full knowledge. Metropolitan Bank denied any liability, claiming that it assumed only certain liabilities connected to banking operations and not employee benefits.
Labor Arbiter’s Decision
The Labor Arbiter dismissed the petitioners' claims, ruling that they were not entitled to additional gratuity pay beyond what they had already received. The Labor Arbiter found that the New Gratuity Plan superseded the Old Plan, and the signing of the quitclaims was valid, concluding that the petitioners understood the implications of their decisions.
NLRC’s Decision
The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision, ruling that the petitioners had no vested rights under the Old Gratuity Plan as it had been replaced by the newer provisions. The NLRC noted that the benefits received under the SSP exceeded the minimum due under the Labor Code for redundancy.
Court of Appeals’ Decision
The CA held that the petitioners' petition for certiorari was dismissible due to their failure to file a motion for reconsideration of the NLRC's decision. Upon reconsideration, the CA similarly denied the request, citing the lack of explanation for the petitioners’ procedural oversight.
Issues Raised
The petitioners raised multiple errors committed by the CA, including the dismissal based on procedural grounds, the NLRC’s findings regarding their rights under the Gratuity Plans, the binding nature of the quitclaims, and the liability of Metropolitan Bank as the acquiring corporation.
Court’s Ruling
The petition was denied b
...continue readingCase Syllabus (G.R. No. 182331)
Nature of the Case
- The case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- Petitioners challenge the Resolutions dated November 7, 2007, and March 26, 2008, from the Court of Appeals in CA-G.R. SP No. 101065.
Antecedent Facts
- Petitioners are regular employees of the Philippine Banking Corporation (Philbank) with at least ten years of service.
- Philbank established an Old Gratuity Pay Plan in 1970, which provided benefits for employees upon retirement or separation.
- The Old Plan entitled employees to a gratuity pay equivalent to one month's salary for every year of service, capped at 24 months' salary.
- A New Gratuity Pay Plan was implemented on March 8, 1991, which offered different terms, particularly for those involuntarily separated.
- In February 2000, Philbank merged with Global Business Bank, Inc. (Globalbank), resulting in redundancy for the petitioners' positions.
- A Special Separation Program (SSP) was offered, providing a separation package of 150% of one month's salary for each year of service.
- Petitioners signed acceptance letters and quitclaims to avail of the SSP benefits.
- In August 2002, Metropolitan Bank and Trust Company (Metrobank) acquired Globalbank's assets and liabilities.
- Petitioners filed complaints for non-payment of separation pay, arguing they were entitled to additional gratuity pay under the Old Plan.
The Labor Arbiter's Decision
- The Labor Arb