Case Summary (G.R. No. 169191)
Background of the Case
The case began when Romeo Villaruel filed a complaint for separation pay against Yuhans Enterprises, owned by Yeo Han Guan. Villaruel asserted that he had been employed by the company since June 1963, with the company undergoing several name changes over the years. He claimed that he was sick in October 1998 and was subsequently not allowed to return to work. Following his refusal of an offered separation pay of PHP 15,000, which did not adequately cover his tenure, he sought full separation pay and additional service incentive leave.
Proceedings in Labor Arbiter and Subsequent Appeals
The Labor Arbiter ruled in favor of Villaruel, awarding him separation pay based on Article 284 of the Labor Code, recognizing his long service with Yuhans Enterprises. The NLRC affirmed this decision upon appeal. However, Yeo Han Guan submitted a certiorari petition to the Court of Appeals, leading to a modification wherein the award of separation pay was deleted, yet the service incentive leave pay remained intact.
Legal Issues Presented in the Petition
Upon challenging the Court of Appeals decision, Villaruel assigned several errors, asserting that the court overlooked evidence of his termination and misapplied the burden of proof regarding entitlement to separation pay. He argued that the Court of Appeals's finding that he voluntarily severed his employment relationship with the respondent was erroneous.
Entitlement to Separation Pay
The Supreme Court reiterated that under Article 284 of the Labor Code, only an employer may terminate an employee due to disease. The issue remained whether Villaruel had been dismissed or if he resigned. Examination of the pleadings revealed that Villaruel consistently indicated no intention to return to work, effectively equating to resignation. His claim for separation pay, therefore, did not align with the stipulations of the Labor Code, which only entitles departing employees to such compensation if dismissed.
Employer's Obligation and Employee’s Resignation
The nature of resignation was highlighted, noting that an employee’s act of severing their employment ties voluntarily negates the basis for claiming separation pay unless otherwise stipulated in contractual terms or company policy. Given the lack of any incriminating record against Villaruel throughout his tenure, it was determined that he was not terminated for any misconduct, but rather he chose not to return due to
...continue readingCase Syllabus (G.R. No. 169191)
Case Overview
- The case revolves around a petition filed by Romeo Villaruel against Yeo Han Guan, who operates as Yuhans Enterprises, concerning a dispute over separation pay and related claims after Villaruel's employment.
- The petition was filed against the backdrop of decisions made by the Court of Appeals (CA) and the National Labor Relations Commission (NLRC) regarding Villaruel's entitlements following the alleged termination of his employment.
- The significant dates include the initial filing of a complaint on February 15, 1999, the Labor Arbiter's decision on November 27, 2000, the NLRC's decision on March 31, 2003, and the CA's decisions on February 16, 2005, and August 2, 2005.
Factual Background
- Villaruel was employed as a machine operator in Ribonette Manufacturing Company, owned by Yeo Han Guan, starting in June 1963.
- The company underwent four name changes, ultimately becoming Yuhans Enterprises in 1993, during which Villaruel remained employed.
- Villaruel was hospitalized due to illness on October 5, 1998, and after his recovery on December 12, 1998, he was not allowed to return to work and was offered a separation pay of P15,000.00, which he deemed insufficient as it only covered a part of his employment duration.
- Respondent Yeo Han Guan argued that Villaruel was not terminated but had chosen not to return to work after his illness.
Labor Arbiter's Decision
- The Labor Arbiter ruled in favor of Villaruel, awarding him separation pay and service incentive leave pay.
- The separation pay was calculated based on his entire length of service from June 1963 to October 1998, totaling P91,4