G.R. No. 165594 ; April 23, 2007
FRANCISCO SORIANO, JR., Petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and PHILIPPINE LONG DISTANCE TELEPHONE COMPANY, INCORPORATED, Respondents.

FACTS

Petitioner Francisco Soriano, Jr., along with three co-employees, was employed by respondent PLDT in 1980 and later promoted to positions involving the manual operation and maintenance of electro-mechanical devices. In November 1995, PLDT implemented a company-wide redundancy program, citing technological changes such as the conversion to modern digital switches, which rendered certain positions superfluous. Consequently, in July 1996, PLDT notified Soriano and his colleagues that their positions were redundant, with termination effective August 1996. Their requests for transfer to other positions were denied. Upon dismissal, they each received substantial separation pay and executed “Receipt, Release and Quitclaim” documents, albeit with the notation “Under Protest” beside their signatures.
Subsequently, Soriano and the others filed a joint complaint for illegal dismissal. The Labor Arbiter dismissed the complaint, finding the redundancy program valid and implemented in good faith due to technological modernization. This decision was affirmed by the NLRC and later by the Court of Appeals. Soriano elevated the case to the Supreme Court via a Petition for Review on Certiorari, arguing the redundancy was not genuine and that the quitclaims were executed under protest, thus invalid.

ISSUE

Whether the dismissal of petitioner on the ground of redundancy was valid.

RULING

The Supreme Court ruled in the affirmative, upholding the validity of the dismissal. The legal logic rests on the established principle that redundancy is a authorized ground for termination under Article 283 of the Labor Code, recognized as a management prerogative exercised in good faith to improve efficiency. The Court found that PLDT sufficiently proved the redundancy was genuine, not merely a pretext for dismissal. The company-wide program was driven by bona fide technological changes—the shift from electro-mechanical to digital systems—which legitimately reduced the need for manual switchmen. PLDT complied with procedural due process by serving a written notice to the employees and the DOLE at least one month prior to termination and by granting separation pay exceeding the statutory requirement.
The Court further held that the execution of quitclaim documents, even with the “Under Protest” notation, did not negate the validity of the termination. The protest pertained to their disagreement with the dismissal itself, not to any vitiation of consent due to fraud or deceit. Having received full separation benefits, which they accepted and retained, they were deemed to have ratified the quitclaims. The consistent findings of the Labor Arbiter, NLRC, and Court of Appeals on the good faith implementation of the redundancy program are accorded finality, as there was no showing of arbitrariness or disregard of evidence. Therefore, the dismissal was legal.