G.R. No. 213486. April 26, 2017
EDITHA M. CATOTOCAN, PETITIONER, V. LOURDES SCHOOL OF QUEZON CITY, INC./LOURDES SCHOOL, INC. AND REV. FR. CESAR F. ACUIN, OFM CAP, RECTOR, RESPONDENTS.

FACTS

Petitioner Editha Catotocan was a teacher at Lourdes School of Quezon City (LSQC) since 1971. In 2003, LSQC issued an addendum to its retirement plan stating that normal retirement occurs upon reaching age 60 or completing 30 years of service, whichever comes first. Catotocan, along with other employees, objected to this 30-year service clause, seeking deferment and requesting to retire at age 60 instead. Despite these objections, LSQC notified Catotocan in January 2005 that she would be retired at the end of the school year for having served over 30 years. She was 56 years old at the time. She was formally retired in June 2006 after 35 years of service and received her full retirement benefits, with 60% paid in lump sum and the balance in monthly installments.
Subsequent to her retirement, Catotocan applied for and was granted re-employment by LSQC under a contractual arrangement for the school year 2006-2007. She worked under such fixed-term contracts for three consecutive school years. After her contract ended in 2009 and her fourth application for re-hiring was denied, she filed a complaint for illegal dismissal, claiming her retirement was involuntary and constituted constructive dismissal.

ISSUE

Whether or not the petitioner was illegally dismissed, rendering her retirement involuntary and invalid.

RULING

The Supreme Court ruled that there was no illegal dismissal and that Catotocan’s retirement was valid. The legal logic hinges on the principle of estoppel and voluntary acceptance. While Catotocan initially opposed the retirement policy, her subsequent actions constituted a clear and voluntary acquiescence to her retirement. Crucially, she accepted and received in full all her retirement benefits without protest. More significantly, she applied for and availed herself of LSQC’s re-hiring program for retirees for three consecutive years. These acts—accepting benefits and seeking re-employment under the new contractual terms—are supervening events that demonstrated her free and voluntary consent to the retirement. The Court distinguished this case from precedents where employees consistently refused benefits, noting that Catotocan’s conduct ratified the retirement. Her complaint for illegal dismissal, filed only after her re-hiring application was denied, was deemed an afterthought. Therefore, her separation was a lawful retirement, not a dismissal.