Title
Mateo vs. Coca-Cola Bottlers Philippines, Inc.
Case
G.R. No. 226064
Decision Date
Feb 17, 2020
Employee terminated due to redundancy received separation pay; deductions contested as tax-exempt under NIRC Sec. 32; Supreme Court ruled in favor, reinstating exemption.

Case Summary (G.R. No. 226064)

Applicable Law

The primary laws applicable in this case include Article 283 of the Labor Code of the Philippines, which governs separations due to redundancy, and Section 32(B)(6)(b) of the National Internal Revenue Code (NIRC) of 1997, concerning the tax treatment of retirement benefits, specifically the exclusion from gross income for amounts received as separation pay.

Factual Background

Anna Mae B. Mateo was previously employed at Philippine Beverage Partners, Inc. (PhilBev) where she served as a Sales Supervisor. Following PhilBev's cessation of operations in 2007, she received separation benefits. Subsequently, she was hired by Coca-Cola Bottlers Phils. Inc. and held the position of District Team Leader until her employment was terminated due to redundancy related to a new Route to Market strategy on March 31, 2012. Upon her dismissal, respondent provided her with partial payment of her separation benefits but deducted withholding tax and outstanding loans from the computed amount.

Procedural History

Initially, the Labor Arbiter ruled in favor of the petitioner, finding the tax deduction on her separation pay as erroneous and ordering the respondent to pay the full separation amount plus attorney's fees. The National Labor Relations Commission (NLRC) affirmed a part of the ruling regarding the separation pay but deleted the award for attorney's fees. Dissatisfied, Coca-Cola Bottlers filed a certiorari petition before the Court of Appeals, which subsequently reversed the NLRC's ruling and dismissed the complaint, leading to the present petition for review.

Issue

The primary issue before the court is whether the respondent, Coca-Cola Bottlers, is liable for the illegal deduction from the petitioner’s separation pay by withholding tax from the amount received due to her involuntary separation from service attributable to redundancy.

Court's Ruling

The court determined that the amount received by the petitioner was classified as separation pay resulting from redundancy and not retirement pay. Given this classification, the court referenced Article 283 of the Labor Code, which establishes that employees separated due to redundancy are entitled to separation pay that is exempt from taxation according to Section 32(B)(6)(b) of the NIRC. The court clarified that despite the employer's retirement plan being implicated i

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