GR 166507; (January, 2007) (Digest)
G.R. No. 166507 ; January 23, 2007
AMKOR TECHNOLOGY PHILIPPINES, INC., ANTHONY MICHAEL PETRUCCI and ROSEMARIE S. KATALBAS, Petitioners, vs. NORY A. JUANGCO, Respondent
FACTS
Petitioner Amkor Technology Philippines, Inc., due to business losses, convened meetings to discuss downsizing. Respondent Nory A. Juangco, the Executive Director, attended a key meeting in October 2001 where she expressed interest in personally participating in the company’s voluntary retirement program. She submitted an undated letter signifying her intention to avail of the program, effective November 15, 2001, and even proposed specific terms for her separation package. A week later, she received the amount of P3,704,517.98 and signed a corresponding Receipt and Release Waiver and Quitclaim.
Subsequently, respondent filed a complaint for illegal dismissal, claiming she signed the retirement documents under duress and intimidation, specifically that she was threatened with receiving nothing if she refused. The National Labor Relations Commission (NLRC) dismissed her complaint, finding the retirement voluntary. The Court of Appeals reversed the NLRC, ruling she was coerced. This Court initially affirmed the appellate court with modification, deleting awards for damages. Petitioners filed a Motion for Partial Reconsideration.
ISSUE
Whether respondent voluntarily retired from her employment, thereby precluding a finding of illegal dismissal.
RULING
The Supreme Court granted the motion for partial reconsideration, reversed its prior Decision, and reinstated the NLRC’s dismissal of the complaint. The Court held that respondent voluntarily retired and was not illegally dismissed. While the Court generally defers to factual findings in a Rule 45 petition, it is compelled to review when the findings of the Court of Appeals conflict with those of the NLRC.
Examining the records, the Court found no evidence of coercion. Intimidation under Article 1335 of the Civil Code requires a reasonable and well-grounded fear of an imminent and grave evil. Respondent, a well-educated individual holding a high managerial position, proactively participated in the meeting, proposed the terms of her package, and received a substantial sum significantly higher than standard statutory benefits. Her educational and professional stature made it highly improbable she was duped. The Court cited analogous rulings in Domondon v. NLRC and Callanta v. NLRC, which held that individuals of high educational attainment are presumed to know the import of documents they execute. Furthermore, her delay of almost six months before filing the complaint suggested it was an afterthought after failing to find new employment. The Court emphasized that while social justice favors labor, management’s rights must also be respected based on the evidence.