Case Summary (G.R. No. 197557)
Factual Background
Maureen P. Perez commenced her employment with Comparts Industries, Inc. on July 16, 1988, attaining regular status by September 1, 1988. She ascended to the position of Marketing Manager by 1998, a role she held until her resignation on January 10, 2009. CII instituted a retirement program for managerial employees under the "Comparts Industries, Inc. Employees Retirement Plan" effective June 1, 1999, and amended January 25, 2001. The retirement plan included provisions for optional or early retirement.
Application for Optional Retirement
In November 2007, Perez expressed her intent to avail herself of the optional retirement program, asserting eligibility, although her application was denied. While she was on vacation in the United States in January 2008, she reapplied, which was also rejected based on CII's asserted financial crisis. Perez later sought reconsideration and requested inclusion in a planned retrenchment, yet her appeals continued to be denied. In December 2008, she submitted a final application for optional retirement effective January 10, 2009, citing personal reasons related to family health. CII offered her a gratuity of PHP 100,000.00, which she refused.
Grounds for Denial
CII formally accepted Perez's resignation, concomitantly denying her claim for optional retirement benefits on several grounds: lack of a policy on optional retirement benefits, financial hardship, absence of legal entitlement for voluntarily resigning employees to separation pay, and the inapplicability of the Collective Bargaining Agreement (CBA) applicable only to rank-and-file employees.
NLRC Ruling
In response to CII's denial, Perez filed a complaint with the National Labor Relations Commission (NLRC) alleging discrimination, seeking either optional retirement benefits under the retirement plan or separation benefits under the CBA. The NLRC-RAB favored Perez, awarding her PHP 422,195.84 in optional retirement benefits, based on her twenty years of service, and referencing instances of other managerial employees receiving separation benefits.
Appeal and Reversal
CII appealed to the NLRC, which reversed the initial ruling and dismissed Perez's complaint. The NLRC based its decision on various grounds, primarily noting CII's prerogative under the retirement plan to grant or deny applications for optional retirement. The Commission emphasized that many managerial employees who received benefits did so prior to the establishment of the retirement plan.
Court of Appeals Decision
Subsequently, Perez sought a review of the NLRC's decision in the Court of Appeals, alleging grave abuse of discretion. The appellate court dismissed her petition and upheld the NLRC's findings, asserting that Perez, as a managerial employee under the retirement plan, required CII's consent for optional retirement. The court cited relevant jurisprudence, notably illustrating that such benefits were not a right but rather a management prerogative.
Supreme Court Findings
The Supreme Court affirmed the appellate court’s ruling, re
Case Syllabus (G.R. No. 197557)
Case Background
- The case concerns a petition for review on certiorari filed by Maureen P. Perez against Comparts Industries, Inc. (CII) under Rule 45 of the Rules of Court.
- The petition contests the Decision of the Court of Appeals in CA-G.R. CEB-SP. No. 05473, which upheld the ruling of the National Labor Relations Commission (NLRC) in NLRC VAC-VAC-02-000085-2010.
- The NLRC had reversed an earlier decision by the NLRC Regional Arbitration Branch No. VII, which had favored Perez, awarding her optional retirement benefits totaling Php422,195.84 plus attorney's fees.
Employment History
- Perez began her employment with CII on July 16, 1988, and became a regular employee on September 1, 1988.
- She was promoted to Marketing Manager and held this position from 1998 until her resignation on January 10, 2009.
Retirement Plan Details
- CII implemented an Employees Retirement Plan effective June 1, 1999, amended on January 25, 2001, which included provisions for optional or early retirement.
- Perez indicated her desire to retire under this plan in November 2007, which was denied by CII. Her subsequent application during a vacation in the United States in January 2008 was also denied.
Reasons for Denial of Retirement Application
- CII cited financial crises as justification for denying Perez's applications for optional retirement, arguing it had the discretion to approve or disapprove applications under the Retirement Plan.
- Perez's request for reconsideration in April 2