G.R. No. 156317. April 26, 2005.
CARLOS F. SALOMON, ET AL., Petitioners, vs. ASSOCIATE OF INTERNATIONAL SHIPPING LINES, INC., Respondent.

FACTS

The respondent company, suffering substantial financial losses from 1996 to 1998, implemented a retrenchment program that led to the closure of its Measuring Department and the termination of seventeen workers, including the petitioners. The petitioners, who held positions as booking coordinators and measurers, received termination letters effective April 30, 1998. The company filed the requisite notice with the DOLE. The petitioners initially filed a complaint for illegal dismissal. During conciliation, they received payments which the company designated as retirement pay, along with other benefits, and subsequently executed Releases and Quitclaims, leading to the closure of that case.
Surprisingly, the petitioners later filed a new complaint before the Labor Arbiter, claiming they were entitled to additional retirement benefits under their Collective Bargaining Agreement (CBA). They argued that what they had received was actually separation pay due to retrenchment under Article 283 of the Labor Code, and that this receipt did not preclude a separate claim for CBA retirement benefits. The Labor Arbiter and the NLRC dismissed their complaint.

ISSUE

Whether the petitioners, who were validly retrenched and received payments which they executed quitclaims for, are still entitled to claim retirement benefits under their CBA.

RULING

The Supreme Court denied the petition and affirmed the rulings of the Court of Appeals and the NLRC. The legal logic hinges on the specific provisions of the parties’ CBA and the nature of the benefits received. The Court distinguished this case from precedents like Aquino v. NLRC where employees were allowed to receive both separation and retirement pay because the governing CBA or plan contained no prohibition against dual entitlement. In the present case, the CBA provision on retirement was explicitly optional for qualified employees. Critically, the petitioners failed to prove that their CBA mandated the grant of retirement benefits in addition to the separation pay legally mandated for retrenchment. The payments they received, although labeled “retirement benefits” in the quitclaims, were correctly treated by the lower tribunals as the separation pay due to them under Article 283 for an authorized cause of termination. The executed quitclaims, which were voluntary, fair, and made with full understanding, thus barred any further claim. The Court deferred to the factual findings of the NLRC, which found no basis for dual entitlement under the specific CBA, and found no grave abuse of discretion in its decision.