GR 158684; (May, 2005) (Digest)
G.R. No. 158684 ; May 16, 2005
PATERNO S. MENDOZA, JR., petitioner, vs. SAN MIGUEL FOODS, INC. and INSTAFOOD CORPORATION OF THE PHILIPPINES, respondents.
FACTS
Petitioner Paterno S. Mendoza, Jr., an employee of San Miguel Foods, Inc. (SMFI), was validly terminated on November 30, 1996, due to a redundancy program. He accepted substantial separation benefits, executed a quitclaim, and availed of a one-month terminal leave. During this terminal leave, however, he was requested by the company to handle a specific task concerning a “return shipment” of goods from the Bureau of Customs. Mendoza performed work on this matter, including meetings and coordination with brokers, extending into December 1996. When he later sought payment for this work, his claim was rejected. Mendoza subsequently filed a complaint for illegal dismissal, arguing that by requiring him to perform his regular duties, the company had impliedly revoked his termination and reinstated him to employment.
ISSUE
Whether the act of requiring the petitioner to perform a specific task during his terminal leave constituted an implied revocation of his valid redundancy termination and effected his reinstatement.
RULING
No. The Supreme Court ruled that Mendoza’s termination remained valid and was not revoked. The legal logic is anchored on the nature of redundancy as an authorized cause for termination and the specific circumstances of the task assigned. The Court found that the work performed by Mendoza was not part of his regular duties as a Purchasing Officer but was a special, limited assignment to assist in resolving a particular problem with a shipment. This task was an isolated incident and did not demonstrate a continuity of service or a restoration of the employer-employee relationship. The company’s act of authorizing him to transact with customs for a finite period was merely a practical accommodation to utilize his familiarity with the pending shipment, not an act of reinstatement. Furthermore, Mendoza had already voluntarily accepted his separation benefits and signed a quitclaim, which, under the circumstances, was deemed a valid and binding waiver as it was executed knowingly and for a consideration far exceeding statutory requirements. The Labor Arbiter’s finding of implied revocation was therefore reversed. The Court of Appeals decision affirming the NLRC’s dismissal of the illegal dismissal complaint was sustained.