Case Summary (A.M. RTJ-20-2600)
Factual Background
Ybarola and Rivera were terminated from their positions on September 15, 2002, following a corporate reorganization by RMN. They received separation pay amounts of P631,250.00 for Ybarola and P481,250.00 for Rivera, and subsequently executed release/quitclaim affidavits. Dissatisfied with their compensation, both filed complaints for illegal dismissal and sought additional money claims, including attorney’s fees, asserting that their salaries were P60,000.00 and P40,000.00 per month.
Compulsory Arbitration Proceedings
The respondents contended that the release/quitclaim should not preclude them from claiming additional benefits as they had signed these documents under dire necessity. RMN asserted that the separation pay was fair and reflected a reasonable settlement. The Labor Arbiter initially dismissed the illegal dismissal complaint but ordered additional separation pay. Upon appeal, the National Labor Relations Commission (NLRC) dismissed the complaint, asserting that the quitclaim was valid and that the inclusion of commissions in calculating separation pay was improper.
The CA Decision and Rulings
On February 17, 2011, the Court of Appeals (CA) overturned the NLRC’s decision, reinstating the Labor Arbiter's separation pay award and ruling that the respondents’ commissions should be included in their salary calculations. The CA deemed the release/quitclaim invalid due to unconscionable terms and lack of voluntariness, underscoring that the respondents were effectively compelled to accept the settlement due to financial pressures.
The Motion for Reconsideration
Following the CA's unfavorable decision, RMN filed a motion for reconsideration, arguing that the CA had erred in not exonerating Canoy personally and in disregarding the proper evaluation of quitclaims. They contended that Canoy bore no individual responsibility for the dismissal and that the burden to demonstrate the legitimacy of the claims regarding commissions rested with the respondents.
Respondents’ Position
The respondents opposed the motion for reconsideration, arguing that the petitioners had previously raised the same arguments and that Canoy’s liability had already become a conclusive matter due to the petitioners’ failure to raise it in earlier stages of the proceedings. They maintained that the claims lacked merit given the context of the respective decisions issued by the NLRC and the CA.
Petitioners' Reply
In their reply, the petitioners insisted that the issues raised had not been adequately addressed and sought reinstatement of their petition. They challenged the notion that Canoy’s liability had been resolved, claiming satisfaction was neither compulsory nor legally sufficient in the prior proceedings.
Court Ruling on the Motion for Reconsideration
The Court ultimately denied the motion for reconsideration, stating the arguments presented were redundant and unconvincing. It reinforced that
...continue readingCase Syllabus (A.M. RTJ-20-2600)
Case Citation
- 694 Phil. 689
- G.R. No. 198662
- September 12, 2012
- Special Second Division
Parties Involved
- Petitioners: Radio Mindanao Network, Inc. (RMN) and Eric S. Canoy
- Respondents: Domingo Z. Ybarola, Jr. and Alfonso E. Rivera, Jr.
Procedural History
- The motion for reconsideration by the petitioners was addressed concerning a prior resolution dated December 7, 2011, which denied their appeal from the decision and resolution of the Court of Appeals (CA) in CA-G.R. SP No. 109016.
Factual Background
Employment History:
- Respondents were employed by RMN: Ybarola since June 15, 1977, and Rivera since June 1, 1983.
- Both eventually became account managers responsible for soliciting advertisements.
Termination and Separation Pay:
- On September 15, 2002, their employment was terminated due to RMN's reorganization.
- They received separation pay: P631,250.00 for Ybarola and P481,250.00 for Rivera.
- In December 2002, the respondents executed release/quitclaim affidavits.
Subsequent Legal Action:
- Dissatisfied with their separation pay, the respondents filed complaints for illegal dismissal and other monetary claims, including attorney’s fees.
- They claimed monthly salaries of P60,000.00 for Ybarola and P40,000.00 for Rivera, while RMN contended they earned P9,177.00 monthly, supported by payroll records.
The Compulsory Arbitration Proceedings
Labor Arbiter's Decision:
- On July 18, 2007, Labor Arbiter Patricio Libo-on dismissed the illegal dismissal complaint but ordered additional separation pay based on the respondents' actual earnings.
NLRC Ruling:
- The NLRC set aside the labor arbiter's decision, ruling that the withholding tax certificate could not be the basis for computing separation pay due to the inclusion of