G.R. No. 185449 November 12, 2014
Goodyear Philippines, Inc. and Remigio M. Ramos, Petitioners, vs. Marina L. Angus, Respondent.

FACTS

Marina L. Angus was employed by Goodyear Philippines, Inc. on November 16, 1966, as Secretary to the Manager of Quality and Technology. Due to economic reversals, Goodyear implemented cost-saving measures, including workforce streamlining. On September 18, 2001, Angus received a letter from Goodyear’s Human Resources Director, Remigio M. Ramos, informing her that her position was redundant and would be abolished, terminating her services effective October 18, 2001. The letter stated that, as company practice, termination due to redundancy is paid at 45 days’ pay per year of service, but since she had rendered 34.92 years of service and had reached the minimum age of 55 to qualify for early retirement, Management decided to grant her early retirement benefit at 47 days’ pay per year of service. Angus responded, accepting the early retirement but proposing an additional premium of 3 days per year of service. On November 20, 2001, Angus accepted checks covering her retirement benefits computed at 47 days’ pay per year of service but annotated the receipt with a protest, stating the amount was not acceptable and claiming separation pay as mandated by law, separate from her early retirement benefit. Due to this annotation and her refusal to sign a Release and Quitclaim, petitioners took back the checks. After correspondence, Angus finally accepted a check for ₱1,958,927.89 on January 17, 2002, inclusive of all termination benefits computed at 47 days’ pay per year of service, and executed a Release and Quitclaim. On February 5, 2002, Angus filed a complaint for illegal dismissal with claims for separation pay, damages, and attorney’s fees. Petitioners argued that the Retirement Plan under the Collective Bargaining Agreement (CBA) and the Employment Contract entitled an employee to only one benefit, citing a CBA provision that availment of retirement benefits excludes entitlement to any separation pay. Angus disputed the existence of this provision, presenting the latest CBA which contained no such prohibition. The Labor Arbiter upheld the validity of Angus’s termination and dismissed her complaint, ruling that the amount she received was separation pay due to redundancy computed under the more advantageous CBA retirement plan and that the grant of both separation and retirement pay was not allowed. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision. The Court of Appeals (CA) partially granted Angus’s Petition for Certiorari, declaring her dismissal valid but entitling her to separation pay in addition to the retirement pay she already received, citing jurisprudence that allows collection of both benefits in the absence of an express or implied prohibition.

ISSUE

Whether respondent Marina L. Angus is entitled to receive both retirement benefits and separation pay upon her termination due to redundancy.

RULING

Yes. The Supreme Court affirmed the decision of the Court of Appeals. The Court ruled that in the absence of an express or implied prohibition against it, the collection of both retirement benefits and separation pay upon severance from employment is allowed. This is grounded on the social justice policy that doubts should always be resolved in favor of labor rights. The Court found that the provision in the CBA cited by petitioners, which stated that availment of retirement benefits excludes entitlement to any separation pay, was not part of the latest CBA presented by Angus. The applicable CBA provision (Section 5, Article VIII) only detailed the computation of retirement benefits and did not contain any prohibition against receiving both benefits. Since there was no express prohibition in the CBA, Retirement Plan, or Employment Contract, Angus was entitled to both benefits. The retirement benefit was a product of the collective negotiation of the union, while separation pay was a statutory right mandated by Article 283 of the Labor Code for termination due to redundancy. The Court also held that the Release and Quitclaim signed by Angus was void for being contrary to law, public policy, and morals, as it sought to prevent her from claiming a statutory right. The CA decision ordering petitioners to pay separation pay, attorney’s fees equivalent to 10% of the separation pay, and moral damages was affirmed.