Case Summary (G.R. No. 212635)
Facts
Rosita De Leon was employed by Manila Hotel Corporation starting September 1, 1976, and progressed through various positions, ultimately becoming the Assistant Credit and Collection Manager. On June 7, 2011, she received a Notice of Compulsory Retirement, effective June 10, 2011, due to her length of service. Respondent claimed that this retirement was enforced without due process and submitted a complaint for illegal dismissal, underpayment of salaries, and other claims against the petitioner and its officers.
Petitioner’s Position
The petitioner maintained that there was no illegal dismissal, arguing that De Leon voluntarily accepted the compulsory retirement offer under the Collective Bargaining Agreement (CBA). Under the CBA, compulsory retirement occurs at age 60 or after 20 years of service. The petitioner asserted that De Leon, despite being only 57 years old, was eligible for compulsory retirement, having exceeded the 20-year service requirement significantly.
Respondent’s Claims
De Leon countered by asserting she never consented to the retirement, arguing that the decision was made unilaterally by the petitioner. She argued that her retirement was a violation of her labor rights and emphasized that the provisions of the CBA regarding retirement did not apply to her managerial status, which granted her different protections.
Ruling of the Labor Arbiter (LA)
The Labor Arbiter ruled in favor of De Leon, determining that she held a managerial position and thus the CBA did not apply. The LA found that the compulsory retirement constituted constructive dismissal, ordered her reinstatement, and awarded back wages, benefits, and damages, while dismissing some of her monetary claims.
Ruling of the National Labor Relations Commission (NLRC)
The NLRC reversed the LA's ruling, stating that De Leon had accepted her retirement. It ruled that while she was a managerial employee—and therefore typically not covered by the CBA—the petitioner's decision to retire her was a valid exercise of management prerogative. The NLRC found that De Leon's alleged acceptance of the retirement offer was evident in her processing of the necessary Personnel Clearance.
Decision of the Court of Appeals (CA)
Upon De Leon's appeal, the CA reinstated the LA's decision, arguing that there was no evidence of her voluntary acceptance of the retirement offer. The CA highlighted that De Leon had consistently questioned her retirement and had filed a complaint against the petitioner, further contradicting any notion of voluntary retirement.
Supreme Court Decision
The Supreme Court affirmed the CA's ruling, decla
...continue readingCase Syllabus (G.R. No. 212635)
Case Overview
- This case is a petition for review on certiorari under Rule 45 of the Rules of Court.
- It concerns the Decision dated March 19, 2015, rendered by the Court of Appeals (CA) in CA-G.R. SP No. 132576.
- The CA set aside the Decision dated June 10, 2013, and Resolution dated September 4, 2013, of the National Labor Relations Commission (NLRC) in NLRC-LAC No. 01-000432-13.
- The NLRC had reversed the Labor Arbiter's (LA) Decision dated December 10, 2012, which dismissed Rosita De Leon's complaint for illegal dismissal.
Background of the Case
- Rosita De Leon began her employment with Manila Hotel Corporation on September 1, 1976, and held various positions, culminating in her role as Assistant Credit and Collection Manager/Acting General Cashier.
- On June 7, 2011, De Leon received a Notice of Compulsory Retirement from the company, effective June 10, 2011, after serving for 35 years.
- At the time of receiving the notice, she was 57 years old and had rendered 34 years of service.
- De Leon subsequently filed a complaint against the company, alleging illegal dismissal and other financial claims.
Claims of the Parties
Respondent (De Leon's Claims):
- Alleged she was coerced into retirement without due process.
- Contended that there was no rational basis for her retirement and claimed management prerogative could not circumvent labor laws.
Petitioner (Manila Hotel Corporation's Claims):
- Argued there was no dismissal as De Leon voluntarily accepted the retirement