Case Summary (G.R. No. L-6408)
Factual Antecedents of the Case
Both respondents were long-term employees of PJI, with de Guzman employed since May 11, 1994, and Quirante since September 5, 1989. They submitted separate requests for retirement under the company's optional retirement plan as established in the CBA, but PJI failed to process these requests, prompting respondents to file a complaint for unfair labor practice, money claims for nonpayment of optional retirement benefits, and other grievances against PJI and its corporate officers.
Decisions in Lower Courts
The Labor Arbiter dismissed the complaint on April 29, 2010, arguing that respondents were not entitled to retirement benefits as they held managerial positions categorized as excluded from the bargaining unit under the CBA. Subsequently, the National Labor Relations Commission (NLRC) reversed this ruling on December 29, 2011, asserting that the existence of an optional retirement plan as per the CBA was clear and that the inclusion in the relevant provisions did not restrict benefits solely to rank-and-file employees.
Ruling of the Court of Appeals
Following an unsuccessful petition for certiorari by PJI, the Court of Appeals (CA) affirmed the NLRC’s decision on November 7, 2012. The CA determined that the optional retirement provisions of the CBA were explicit, qualifying that employees who had rendered five continuous years of service could retire optionally irrespective of management’s approval provided that employees believed they were following a precedent established by the company’s past practices.
Petitioners' Arguments
PJI contended that there exists a clear distinction between compulsory and optional retirement benefits. They argued that without an approved retirement plan, optional retirement cannot be demanded as a matter of right. They raised claims of suffering business losses and highlighted a lack of express company policy on optional retirement that could protect respondents' entitlement to these benefits.
Respondents’ Position and Court's Ruling
The respondents argued that the CBA's language clearly provided for optional retirement benefits. The Court noted that despite the formal classification of respondents’ positions, PJI had historically granted retirement benefits to other managerial employees as a matter of practice, thus forming a binding precedent. The CA highlighted the issue of discrimination against respondents, noting that their actions were consistent with company practice as established in previous cases.
Bad Faith of Petitioners
The Court identified PJI’s actions as evidence of bad faith, based on its inconsistent treatment of employees regarding retirement benefits and its failure to engage with respondents about their retirement status despite their retirement
...continue readingCase Syllabus (G.R. No. L-6408)
Case Citation
- 850 Phil. 1028; 116 OG No. 12, 2437 (March 23, 2020)
- G.R. No. 208027, April 01, 2019
Parties Involved
- Petitioners: Philippine Journalists, Inc., Roland De Jesus, Fe Siscar, Eugenia Abania, Sarah Buan, Francis Rivadelo, and Michael Mosqueda
- Respondents: Erika Marie R. De Guzman and Edna Quirante
Procedural History
- The case is a Petition for Review on Certiorari seeking to reverse the November 7, 2012 Decision and July 4, 2013 Resolution of the Court of Appeals (CA).
- The CA dismissed the Petition for Certiorari in CA-G.R. SP-No. 123901 and denied the petitioners' Motion for Reconsideration.
Factual Antecedents
- Employment History:
- Erika Marie R. De Guzman: Employed by PJI since May 11, 1994, as an Ad Taker/Account Executive, earning Php 23,000.00 plus commission, left on November 15, 2008.
- Edna Quirante: Employed since September 5, 1989, as HRD Supervisor, earning Php 25,522.20, left on March 15, 2009.
- Retirement Applications:
- Both respondents applied for optional retirement benefits as per the company’s Collective Bargaining Agreement (CBA).
- Complaint Filed:
- Due to PJI's failure to process their retirement benefits, respondents filed a complaint for unfair labor practice and nonpayment of optional retirement benefits against PJI.
Ruling of the Labor Arbiter
- Dismissed the complaint for lack of merit, stating that the respondents were managerial employees excluded from the bargaining unit and, therefore, not entitled to optional retirement benefits.
Ruling of the National Labor Relations Commission (NLRC)
- The NLRC reversed