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Prof. Joselito Guianan Chan's The Labor Code of the Philippines, Annotated Labor Standards & Social Legislation Volume I of a 3-Volume Series 2019 Edition (3rd Revised Edition)
 

 
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UNITED STATES SUPREME COURT JURISPRUDENCE
 

 
PHILIPPINE SUPREME COURT JURISPRUDENCE
 

   
October-2014 Jurisprudence                 

  • A.M. No. RTJ-08-2140 (Formerly A.M. No. 00-2-86-RTC), October 07, 2014 - OFFICE OF THE COURT ADMINISTRATOR, Complainant, v. EXECUTIVE JUDGE OWEN B. AMOR, REGIONAL TRIAL COURT, DAET, CAMARINES NORTE, Respondent.

  • A.C. No. 7919, October 08, 2014 - DOMADO DISOMIMBA SULTAN, Complainant, v. ATTY. CASAN MACABANDING, Respondent.

  • A.M. No. P-14-3246 [Formerly A.M. OCA I.P.I. No. 11-3580-P], October 15, 2014 - ATTY. RICO PAOLO R. QUICHO, REPRESENTING BANK OF COMMERCE, Complainant, v. BIENVENIDO S. REYES, JR. , SHERIFF IV, BRANCH 98, REGIONAL TRIAL COURT, QUEZON CITY, Respondent.

  • G.R. No. 205821, October 01, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. GARRY DELA CRUZ Y DE GUZMAN, Accused-Appellant.

  • G.R. No. 188753, October 01, 2014 - AM-PHIL FOOD CONCEPTS, INC., Petitioner, v. PAOLO JESUS T. PADILLA, Respondent.

  • G.R. No. 198528, October 13, 2014 - MAGSAYSAY MITSUI OSK MARINE, INC. AND/OR MOL TANKSHIP MANAGEMENT (ASIA) PTE LTD., Petitioners, v. JUANITO G. BENGSON,* Respondent.

  • A.M. No. P-14-3217 (Formerly OCA IPI NO. 14-4252-RTJ), October 08, 2014 - RE: ANONYMOUS LETTER, Complainant, v. JUDGE CORAZON D. SOLUREN, PRESIDING JUDGE, AND RABINDRANATH A. TUZON, LEGAL RESEARCHER II, BOTH OF BRANCH 91, REGIONAL TRIAL COURT, BALER, AURORA, Respondents.

  • G.R. No. 196005, October 01, 2014 - PEOPLE OF THE PHILIPPINES, Appellee, v. CHARLIE FIELDAD, RYAN CORNISTA, AND EDGAR PIMENTEL, Appellants.

  • G.R. No. 189358, October 08, 2014 - CENTENNIAL GUARANTEE ASSURANCE CORPORATION, Petitioner, v. UNIVERSAL MOTORS CORPORATION, RODRIGO T. JANEO, JR., GERARDO GELLE, NISSAN CAGAYAN DE ORO DISTRIBUTORS, INC., JEFFERSON U. ROLIDA, AND PETER YAP, Respondents.

  • G.R. No. 198636, October 08, 2014 - ESPERANZA C. CARINAN, Petitioner, v. SPOUSES GAVINO CUETO AND CARMELITA CUETO, Respondents.

  • G.R. No. 183272, October 15, 2014 - SUN LIFE OF CANADA (PHILIPPINES), INC., Petitioner, v. SANDRA TAN KIT AND THE ESTATE OF THE DECEASED NORBERTO TAN KIT, Respondents.

  • G.R. No. 198878, October 15, 2014 - RESIDENTS OF LOWER ATAB & TEACHERS’ VILLAGE, STO. TOMAS PROPER BARANGAY, BAGUIO CITY, REPRESENTED BY BEATRICE T. PULAS, CRISTINA A. LAPPAO. MICHAEL MADIGUID, FLORENCIO MABUDYANG AND FERNANDO DOSALIN, Petitioners, v. STA. MONICA INDUSTRIAL & DEVELOPMENT CORPORATION, Respondent.

  • G.R. No. 185745, October 15, 2014 - SPOUSES DOMINADOR MARCOS AND GLORIA MARCOS, Petitioners, v. HEIRS OF ISIDRO BANGI AND GENOVEVA DICCION, REPRESENTED BY NOLITO SABIANO, Respondents.

  • G.R. No. 193650, October 08, 2014 - GEORGE PHILIP P. PALILEO AND JOSE DE LA CRUZ, Petitioners, v. PLANTERS DEVELOPMENT BANK, Respondent.

  • G.R. No. 190161, October 13, 2014 - ANITA N. CANUEL, FOR HERSELF AND ON BEHALF OF HER MINOR CHILDREN, NAMELY: CHARMAINE, CHARLENE, AND CHARL SMITH, ALL SURNAMED CANUEL, Petitioners, v. MAGSAYSAY MARITIME CORPORATION, EDUARDO U. MANESE, AND KOTANI SHIPMANAGEMENT LIMITED, Respondents.

  • G.R. No. 176492, October 20, 2014 - MARIETTA N. BARRIDO, Petitioner, v. LEONARDO V. NONATO, Respondent.

  • G.R. No. 197228, October 08, 2014 - DUTY FREE PHILIPPINES, Petitioner, v. BUREAU OF INTERNAL REVENUE, REPRESENTED BY HON. ANSELMO G. ADRIANO, ACTING REGIONAL DIRECTOR, REVENUE REGION NO. 8, MAKATI CITY, Respondent.

  • G.R. No. 197380, October 08, 2014 - ELIZA ZUÑIGA-SANTOS,* REPRESENTED BY HER ATTORNEY-IN FACT, NYMPHA Z. SALES, Petitioners, v. MARIA DIVINA GRACIA SANTOS-GRAN** AND REGISTER OF DEEDS OF MARIKINA CITY, Respondents.

  • G.R. No. 191225, October 13, 2014 - ZARSONA MEDICAL CLINIC, Petitioner, v. PHILIPPINE HEALTH INSURANCE CORPORATION, Respondent.

  • G.R. No. 203583, October 13, 2014 - LEONORA B. RIMANDO, Petitioner, v. SPOUSES WINSTON AND ELENITA ALDABA AND PEOPLE OF THE PHILIPPINES, Respondents.

  • G.R. No. 187240, October 15, 2014 - CARLOS A. LORIA, Petitioner, v. LUDOLFO P. MUÑOZ, JR., Respondent.

  • G.R. No. 204800, October 14, 2014 - NATIONAL TRANSMISSION CORPORATION, Petitioner, v. COMMISSION ON AUDIT, ATTY. JOSEPHINE A. TILAN, REGIONAL CLUSTER DIRECTOR AND MR. ROBERTO G. PADILLA, STATE AUDITOR IV, Respondents.

  • G.R. No. 191838, October 20, 2014 - YKR CORPORATION, MA. TERESA J. YULO-GOMEZ, JOSE ENRIQUE J. YULO, MA. ANTONIA J. YULO-LOYZAGA, JOSE MANUEL J. YULO, MA. CARMEN J. YULO AND JOSE MARIA J. YULO, Petitioners, v. PHILIPPINE AGRI-BUSINESS CENTER CORPORATION, Respondent.; G.R. No. 191863 - REPUBLIC OF THE PHILIPPINES, Petitioner, v. PHILIPPINE AGRI-BUSINESS CENTER CORPORATION, Respondent.

  • G.R. No. 192518, October 15, 2014 - PHILIPPINE LONG DISTANCE TELEPHONE COMPANY AND/OR ERNANI TUMIMBANG, Petitioners, v. HENRY ESTRANERO, Respondent.

  • G.R. No. 194884, October 22, 2014 - IMASEN PHILIPPINE MANUFACTURING CORPORATION, Petitioner, v. RAMONCHITO T. ALCON AND JOANN S. PAPA, Respondents.

  • G.R. No. 186223, October 01, 2014 - COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. PHILIPPINE ASSOCIATED SMELTING AND REFINING CORPORATION, Respondent.

  • G.R. No. 191101, October 01, 2014 - SPOUSES MARIO OCAMPO AND CARMELITA F. OCAMPO, Petitioners, v. HEIRS OF BERNARDINO U. DIONISIO, REPRESENTED BY ARTEMIO SJ. DIONISIO, Respondents.

  • A.M. No. P-14-3271 [formerly OCA IPI No. 11-3640-P], October 22, 2014 - ATTY. ALAN A. TAN, Complainant, v. ELMER S. AZCUETA, PROCESS SERVER, REGIONAL TRIAL COURT, BRANCH 22, IMUS, CAVITE, Respondent.

  • G.R. No. 188066, October 22, 2014 - OFFICE OF THE OMBUDSMAN, Petitioner, v. CYNTHIA E. CABEROY, Respondent.

  • G.R. No. 192150, October 01, 2014 - FEDERICO SABAY, Petitioner, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • G.R. No. 195832, October 01, 2014 - FORMERLY INC SHIPMANAGEMENT, INCORPORATED (NOW INC NAVIGATION CO. PHILIPPINES, INC.), REYNALDO M. RAMIREZ AND/OR INTERORIENT NAVIGATION CO., LTD./LIMASSOL, CYPRUS, Petitioners, v. BENJAMIN I. ROSALES, Respondent.

  • G.R. No. 191034, October 01, 2014 - AGILE MARITIME RESOURCES INC., ATTY. IMELDA LIM BARCELONA AND PRONAV SHIP MANAGEMENT, INC., Petitioners, v. APOLINARIO N. SIADOR, Respondent.

  • A.M. NO. P-09-2691 (FORMERLY A.M. OCA IPI NO. 09-3040-P), October 13, 2014 - IRENEO GARCIA, RECORDS OFFICER I, METROPOLITAN TRIAL COURT, OFFICE OF THE CLERK OF COURT, CALOOCAN CITY, Complainant, v. CLERK OF COURT IV ATTY. MONALISA A. BUENCAMINO, RECORDS OFFICER II JOVITA P. FLORES AND PROCESS SERVER SALVADOR F. TORIAGA, ALL OF METROPOLITAN TRIAL COURT, OFFICE OF THE CLERK OF COURT, CALOOCAN CITY, Respondents.; A.M. No. P-09-2687 (Formerly A.M. OCA IPI No. 09-3093-P) - EXECUTIVE JUDGE MARIAM G. BIEN, METROPOLITAN TRIAL COURT, BRANCH 53, CALOOCAN CITY, Complainant, v. IRENEO GARCIA, RECORDS OFFICER I AND SALVADOR F. TORIAGA, PROCESS SERVER, BOTH OF THE METROPOLITAN TRIAL COURT, OFFICE OF THE CLERK OF COURT, CALOOCAN CITY, Respondents.; A.M. NO. P-14-3247 (FORMERLY A.M. OCA IPI NO. 09-3238-P) - CLERK OF COURT IV ATTY. MONALISA A. BUENCAMINO, RECORDS OFFICER II JOVITA P. FLORES, AND PROCESS SERVER SALVADOR F. TORIAGA OF THE METROPOLITAN TRIAL COURT, OFFICE OF THE CLERK OF COURT, CALOOCAN CITY, Complainants, v. IRENEO GARCIA AND UTILITY WORKER I HONEYLEE VARGAS GATBUNTON-GUEVARRA, Respondents.

  • G.R. No. 192573, October 22, 2014 - RICARDO N. AZUELO, Petitioner, v. ZAMECO II ELECTRIC COOPERATIVE, INC., Respondent.

  • G.R. No. 192026, October 01, 2014 - AUTOMAT REALTY AND DEVELOPMENT CORPORATION, LITO CECILIA AND LEONOR LIM, Petitioners, v. SPOUSES MARCIANO DELA CRUZ, SR. AND OFELIA DELA CRUZ, Respondents.

  • A.M. No. P-14-3252 [Formerly OCA IPI No. 08-2960-P], October 14, 2014 - JUDGE JUAN GABRIEL H. ALANO, Complainant, v. PADMA L. SAHI, COURT INTERPRETER, MUNICIPAL CIRCUIT TRIAL COURT, MALUSO, BASILAN, Respondent.

  • G.R. No. 172505, October 01, 2014 - ANTONIO M. GARCIA, Petitioner, v. FERRO CHEMICALS, INC., Respondent.

  • G.R. No. 174938, October 01, 2014 - GERARDO LANUZA, JR. AND ANTONIO O. OLBES, Petitioners, v. BF CORPORATION, SHANGRI-LA PROPERTIES, INC., ALFREDO C. RAMOS, RUFO B. COLAYCO, MAXIMO G. LICAUCO III, AND BENJAMIN C. RAMOS, Respondents.

  • G.R. No. 206234, October 22, 2014 - HEIRS OF JULIO SOBREMONTE AND FELIPA LABAPIS SOBREMONTE, NAMELY, MARIA LOURDES SOBREMONTE DE NORBE, DIOSCORA SOBREMONTE DE BUSLON, NESTOR L. SOBREMONTE, AVELINA SOBREMONTE DE DELIGERO, HELEN SOBREMONTE DE CABASE, LAURA SOBREMONTE DE DAGOY AND RODULFO LABAPIS REPOLLO, ALL REPRESENTED BY AVELINA SOBREMONTE DELIGERO AS THEIR ATTORNEY-IN-FACT, Petitioners, v. COURT OF APPEALS, HONORABLE VIRGILIO REYES, IN HIS CAPACITY AS SECRETARY OF THE DEPARTMENT OF AGRARIAN REFORM AND FELICIANO TAPIL, MARCELO BAYNO, VICENTE BAYNO, ROMUALDO DIAPANA, HILARIO RECTA, NEMESIA RECTA, POLICARPIO RECTA, AMPARO R. DIAPANA, BASILIO SAYSON BUENAVENTURA BAYNO AND BASILIO BAFLOR, Respondent.

  • G.R. No. 163654, October 08, 2014 - BPI EXPRESS CARD CORPORATION,* Petitioner, v. MA. ANTONIA R. ARMOVIT, Respondent.

  • G.R. No. 164277, October 08, 2014 - FE U. QUIJANO, Petitioner, v. ATTY. DARYLL A. AMANTE, Respondent.

  • G.R. No. 183700, October 13, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. PABLITO ANDAYA Y REANO, Accused-Appellant.

  • G.R. No. 169568, October 22, 2014 - ROLANDO ROBLES, REPRESENTED BY ATTY. CLARA C. ESPIRITU, Petitioner, v. FERNANDO FIDEL YAPCINCO, PATROCINIO B. YAPCINCO, MARIA CORAZON B. YAPCINCO, AND MARIA ASUNCION B. YAPCINCO-FRONDA, Respondents.

  • A.M. No. P-14-3278 [Formerly A.M. OCA IPI No. 09-3222-P], October 21, 2014 - CONCERNED CITIZENS OF NAVAL, BILIRAN, Complainants, v. FLORANTE F. RALAR, COURT STENOGRAPHER III, REGIONAL TRIAL COURT, BRANCH 37, CAIBIRAN, BILIRAN, Respondent.

  • G.R. No. 200857, October 22, 2014 - FVR SKILLS AND SERVICES EXPONENTS, INC. (SKILLEX), FULGENCIO V. RANA AND MONINA R. BURGOS, Petitioners, v. JOVERT SEVA, JOSUEL V. VALENCERINA, JANET ALCAZAR, ANGELITO AMPARO, BENJAMIN ANAEN, JR., JOHN HILBERT BARBA, BONIFACIO BATANG, JR., VALERIANO BINGCO, JR., RONALD CASTRO, MARLON CONSORTE, ROLANDO CORNELIO, EDITO CULDORA, RUEL DUNCIL, MERV1N FLORES, LORD GALISIM, SOTERO GARCIA, JR., REY GONZALES, DANTE ISIP, RYAN ISMEN, JOEL JUNIO, CARLITO LATOJA, ZALDY MARRA, MICHAEL PANTANO, GLENN PILOTON, NORELDO QUIRANTE, ROEL RANCE, RENANTE ROSARIO AND LEONARDA TANAEL, Respondents.

  • A.M. No. P-09-2673 (A.M. OCA IPI No. 00-857-P), October 21, 2014 - FRUMENCIO E. PULGAR, Petitioner, v. PAUL M. RESURRECCION AND MARICAR M. EUGENIO, Respondents.

  • G.R. No. 166441, October 08, 2014 - NORBERTO CRUZ Y BARTOLOME, Petitioner, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • G.R. No. 175507, October 08, 2014 - RAMON CHING AND PO WING PROPERTIES, INC., Petitioners, v. JOSEPH CHENG, JAIME CHENG, MERCEDES IGNE1 AND LUCINA SANTOS, Respondents.

  • G.R. No. 183421, October 22, 2014 - COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. AICHI FORGING COMPANY OF ASIA, INC., Respondent.

  • G.R. No. 208169, October 08, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. EDWARD ADRIANO Y SALES, Accused-Appellant.

  • G.R. No. 204964, October 15, 2014 - REMIGIO D. ESPIRITU AND NOELAGUSTIN, Petitioners, v. LUTGARDA TORRES DEL ROSARIO REPRESENTED BY SYLVIA R. ASPERILLA, Respondents.

  • G.R. No. 190021, October 22, 2014 - COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. BURMEISTER AND WAIN SCANDINAVIAN CONTRACTOR MINDANAO, INC., Respondent.

  • G.R. No. 173988, October 08, 2014 - FELINA ROSALDES, Petitioner, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • G.R. No. 200454, October 22, 2014 - HOLY TRINITY REALTY & DEVELOPMENT CORPORATION, Petitioner, v. VICTORIO DELA CRUZ, LORENZO MANALAYSAY, RICARDO MARCELO, JR. AND LEONCIO DE GUZMAN, Respondents.

  • G.R. No. 191090, October 13, 2014 - EXTRAORDINARY DEVELOPMENT CORPORATION, Petitioner, v. HERMINIA F. SAMSON-BICO AND ELY B. FLESTADO, Respondents.

  • G.R. No. 160107, October 22, 2014 - SPOUSES JAIME SEBASTIAN AND EVANGELINE SEBASTIAN, Petitioners, v. BPI FAMILY BANK, INC., CARMELITA ITAPO AND BENJAMIN HAO, Respondents.

  • G.R. No. 187702, October 22, 2014 - SECURITIES AND EXCHANGE COMMISSION, Petitioner, v. THE HONORABLE COURT OF APPEALS, OMICO CORPORATION, EMILIO S. TENG AND TOMMY KIN HING TIA, Respondents.; G.R. NO. 189014 - ASTRA SECURITIES CORPORATION, Petitioner, v. OMICO CORPORATION, EMILIO S. TENG AND TOMMY KIN HING TIA, Respondents.

  • G.R. No. 166414, October 22, 2014 - GODOFREDO ENRILE AND DR. FREDERICK ENRILE, Petitioners, v. HON. DANILO A. MANALASTAS (AS PRESIDING JUDGE, REGIONAL TRIAL COURT OF MALOLOS BULACAN, BR. VII), HON. ERANIO G. CEDILLO, SR., (AS PRESIDING JUDGE, MUNICIPAL TRIAL COURT OF MEYCAUAYAN, BULACAN, BR. 1) AND PEOPLE OF THE PHILIPPINES, Respondents.

  • G.R. No. 187581, October 20, 2014 - PHILIPPINE BANK OF COMMUNICATIONS, Petitioner, v. BASIC POLYPRINTERS AND PACKAGING CORPORATION, Respondent.

  • G.R. No. 197442, October 22, 2014 - MAJESTIC FINANCE AND INVESTMENT CO., INC., Petitioner, v. JOSE D. TITO, Respondent.; CORNELIO MENDOZA AND PAULINA CRUZ, Petitioners-Intervenors, v. JOSE NAZAL AND ROSITA NAZAL, Respondents-Intervenors.

  • G.R. No. 167225, October 22, 2014 - RADIO MINDANAO NETWORK, INC., Petitioner, v. MICHAEL MAXIMO R. AMURAO III, Respondent.

  • G.R. No. 192912, October 03, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. DEMOCRITO PARAS, Accused-Appellants.

  • G.R. No. 205249, October 15, 2014 - SPOUSES BENEDICT AND SANDRA MANUEL, Petitioners, v. RAMON ONG, Respondent.

  • G.R. No. 208976, October 13, 2014 - THE HONORABLE OFFICE OF THE OMBUDSMAN, Petitioner, v. LEOVIGILDO DELOS REYES, JR. Respondent.

  • G.R. No. 207629, October 22, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. ARNEL VILLALBA Y DURAN AND RANDY VILLALBA Y SARCO, Accused-Appellants.

  • G.R. No. 181760, October 14, 2014 - ATTY. ANACLETO B. BUENA, JR., MNSA, IN HIS CAPACITY AS REGIONAL DIRECTOR OF REGIONAL OFFICE NO. XVI, CIVIL SERVICE COMMISSION, AUTONOMOUS REGION IN MUSLIM MINDANAO, COTABATO CITY, Petitioner, v. DR. SANGCAD D. BENITO, Respondent.

  • G.R. No. 196315, October 22, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. LEONARDO CATAYTAY Y SILVANO, Accused-Appellant.

  • G.R. No. 201565, October 13, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. EX-MAYOR CARLOS ESTONILO, SR., MAYOR REINARIO “REY” ESTONILO, EDELBRANDO ESTONILO A.K.A. “EDEL ESTONILO,” EUTIQUIANO ITCOBANES A.K.A. “NONONG ITCOBANES,” NONOY ESTONILO-AT LARGE, TITING BOOC-AT LARGE, GALI ITCOBANES-AT LARGE, ORLANDO TAGALOG MATERDAM A.K.A. “NEGRO MATERDAM,” AND CALVIN DELA CRUZ A.K.A. “BULLDOG DELA CRUZ,” Accused, - EX-MAYOR CARLOS ESTONILO, SR., MAYOR REINARIO “REY” ESTONILO, EDELBRANDO ESTONILO A.K.A. “EDEL ESTONILO,” EUTIQUIANO ITCOBANES A.K.A. “NONONG ITCOBANES,” AND CALVIN DELA CRUZ A.K.A. “BULLDOG DELA CRUZ,” Accused-Appellants.

  • G.R. No. 187061, October 08, 2014 - CELERINA J. SANTOS, Petitioner, v. RICARDO T. SANTOS, Respondent.

  • G.R. No. 188801, October 15, 2014 - ROSARIO MATA CASTRO AND JOANNE BENEDICTA CHARISSIMA M. CASTRO, A.K.A. "MARIA SOCORRO M. CASTRO" AND "JAYROSE M. CASTRO," Petitioners, v. JOSE MARIA JED LEMUEL GREGORIO AND ANA MARIA REGINA GREGORIO, Respondents.

  • A.M. No. P-14-3237 [Formerly OCA IPI No. 09-3256-P], October 21, 2014 - JEAN PAUL V. GILLERA, SUZETTE P. GILLERA, ATTY. JILLINA M. GERODIAS, AND IBARRA BARCEBAL, Complainants, v. MARIA CONSUELO JOIE A. LEONEN, AND FAJARDO, SHERIFF IV, REGIONAL TRIAL COURT, BRANCH 93, SAN PEDRO, LAGUNA, Respondent.

  • G.R. No. 177332, October 01, 2014 - NATIONAL POWER CORPORATION, Petitioner, v. CITY OF CABANATUAN, REPRESENTED BY ITS CITY MAYOR, HON. HONORATO PEREZ, Respondents.

  • G.R. No. 188487, October 22, 2014 - VAN D. LUSPO, Petitioner, v, PEOPLE OF THE PHILIPPINES, Respondent.; G.R. No. 188541 - SUPT. ARTURO H. MONTANO AND MARGARITA B. TUGAOEN, Petitioners, v. PEOPLE OF THE PHILIPPINES, Respondent.; G.R. No. 188556 - C/INSP. SALVADOR C. DURAN, SR., Petitioner, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • G.R. No. 203254, October 08, 2014 - DR. JOY MARGATE LEE, Petitioner, v. P/SUPT. NERI A. ILAGAN, Respondent.

  • G.R. No. 164686, October 22, 2014 - FOREST HILLS GOLF AND COUNTRY CLUB, INC., Petitioner, v. GARDPRO, INC., Respondent.

  • G.R. No. 173548, October 15, 2014 - ONOFRE ANDRES, SUBSTITUTED BY HIS HEIRS, NAMELY: FERDINAND, ROSALINA, ERIBERTO, FROILAN, MA. CLEOFE, NELSON, GERMAN, GLORIA, ALEXANDER, MAY, ABRAHAM, AND AFRICA, ALL SURNAMED ANDRES, Petitioners, v. PHILIPPINE NATIONAL BANK, Respondents.

  • G.R. Nos. 176935-36, October 20, 2014 - ZAMBALES II ELECTRIC COOPERATIVE, INC. (ZAMECO II) BOARD OF DIRECTORS, NAMELY, JOSE S. DOMINGUEZ (PRESIDENT), ISAIAS Q. VIDUA (VICE-PRESIDENT), VICENTE M . BARRETO (SECRETARY), JOSE M. SANTIAGO (TREASURER), JOSE NASERIV C. DOLOJAN, JUAN D. FERNANDEZ AND HONORIO L. DILAG, JR. (MEMBERS), Petitioners, v. CASTILLEJOS CONSUMERS ASSOCIATION, INC. (CASCONA), REPRESENTED BY DOMINADOR GALLARDO, DAVID ESPOSO, CRISTITA DORADO, EDWIN CORPUZ, E. ROGER DOROPAN, JOSEFINA RAMIREZ, FERNANDO BOGNOT, JR., CARMELITA DE GUZMAN, MAXIMO DE LOS SANTOS, AURELIO FASTIDIO, BUENAVENTURA CELIS, ROBERTO LADRILLO, CORAZON ACAYAN, CARLITO CARREON, EDUARDO GARCIA, MARCIAL VILORIA, FILETO DE LEON AND MANUEL LEANDER, Respondents; ZAMBALES II ELECTRIC COOPERATIVE, INC. (ZAMECO II) BOARD OF DIRECTORS, JOSE S. DOMINGUEZ (PRESIDENT), ISAIAS Q. VIDUA (VICE-PRESIDENT), VICENTE M . BARRETO (SECRETARY), JOSE M. SANTIAGO (TREASURER), JOSE NASERIV C. DOLOJAN, JUAN D. FERNANDEZ AND HONORIO L. DILAG, JR. (MEMBERS), Petitioners, v. NATIONAL ELECTRIFICATION ADMINISTRATION (NEA) NEA-OFFICE OF THE ADMINISRATIVE COMMITTEE, ENGR. PAULINO T. LOPEZ AND CASTILLEJOS CONSUMERS ASSOCIATION, INC. (CASCONA), Respondents.

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    G.R. No. 167225, October 22, 2014 - RADIO MINDANAO NETWORK, INC., Petitioner, v. MICHAEL MAXIMO R. AMURAO III, Respondent.

      G.R. No. 167225, October 22, 2014 - RADIO MINDANAO NETWORK, INC., Petitioner, v. MICHAEL MAXIMO R. AMURAO III, Respondent.

    PHILIPPINE SUPREME COURT DECISIONS

    FIRST DIVISION

    G.R. No. 167225, October 22, 2014

    RADIO MINDANAO NETWORK, INC., Petitioner, v. MICHAEL MAXIMO R. AMURAO III, Respondent.

    D E C I S I O N

    BERSAMIN, J.:

    This appeal deals with the issue of whether the quitclaim executed by the employee was valid and effective against him.

    Antecedents

    On February 16, 1989, petitioner Radio Mindanao Network, Inc. (RMN) hired respondent Michael Maximo R. Amurao III (Michael) as a radio broadcaster for its DWKC-FM station and production manager for its metropolitan radio operations at a monthly salary of P28,400.00.1

    Years later, RMN decided to reformat and restructure the programming of its DWKC-FM station to meet the demands of the broadcasting industry. On April 25, 2002, the president of RMN met with Michael and other personnel of the station to inform them of the management’s decision, advising them that the reformatting and restructuring of the station’s programs would necessarily affect their employment; but assuring that they would be paid their retirement pay and other benefits.2 To formalize the discussions had in their meeting, RMN furnished Michael and other personnel separate letters dated May 14, 2002 reading as follows:chanRoblesvirtualLawlibrary

    This is to formalize your meeting with our President Mr. Eric S. Canoy, last April 25, 2002. During said meeting, you have been informed that in line with the Network’s reformatting/restructuring program for operations, your services are deemed ended effective June 15, 2002. However, effective May 16, 2002, you will no longer [be] required to report for work. And for the services you have rendered, Radio Mindanao Network, Inc. will pay your separation benefits, service incentive leave pay, proportionate 13th month pay and salary for the month of May 16 to June 15, 2002.

    Radio Mindanao Network, Inc. extends its gratitude and prayers to you and to your loved ones.

    Thank you and God bless.3ChanRoblesVirtualawlibrary

    However, Michael and the other personnel refused to sign in receipt when the letters were served on them. Not long after, however, they accepted the offer of RMN and executed affidavits relinquishing all their claims against the employer. In Michael’s case, the Affidavit of Release/Quitclaim Dated May 30, 2002 (quitclaim) stated as follows:chanRoblesvirtualLawlibrary

    AFFIDAVIT OF RELEASE/QUITCLAIM

    That I, MICHAEL MAXIMO R. AMURAO III, of legal age, Filipino, and a resident of Manila after having been duly sworn to according to law, hereby depose and say:chanRoblesvirtualLawlibrary

    1. That I have retired from my position as Production Manager from RADIO MINDANAO NETWORK INC. EFFECTIVE June 15, 2002;cralawlawlibrary

    2. That for and in consideration of sum THREE HUNDRED ELEVEN THOUSAND NINE HUNDRED TWENTY-TWO PESOS & 00 CENTS. (P311,922.00) in Philippine Currency, to me in hand paid by RADIO MINDANAO NETWORK, INC. in additional retirement benefits per corrected employment period, receipt of which is hereby acknowledged to my complete and full satisfaction;cralawlawlibrary

    3. That I hereby RELEASE AND DISCHARGE RADIO MINDANAO NETWORK, INC., its Officers, Directors, and Managers from any and all claims and demands whatsoever as maybe due to me incident to employment with radio station DWKC-FM and/or cessation of the same with Radio Mindanao Network, Inc., on June 15, 2002.

    4. That I hereby state further that I have no more claims, right or action whatsoever nature whether past, present or contingent against said corporation;cralawlawlibrary

    5. That, I manifest that the terms of this release and quitclaim have been read and thoroughly understood by me and accepted said terms on my own consent.”4

    On October 14, 2002, or 5 months after receiving his benefits and his execution of the quitclaim, Michael filed a complaint against RMN for illegal dismissal with money claims in the National Labor Relations Commission (NLRC).5

    Decision of the Labor Arbiter

    On November 12, 2002, the Labor Arbiter rendered a decision6 declaring the dismissal of Michael as illegal on the ground that the reformatting and restructuring of RMN’s radio programming did not fall under any of the just or authorized causes specified under Article 282, Article 283 and Article 284 of the Labor Code that would make the termination of his employment valid; and holding the quitclaim Michael signed as void because it was not voluntarily executed. The decision disposed thusly:chanRoblesvirtualLawlibrary

    WHEREFORE, premises considered, judgment is hereby rendered declaring that the dismissal of the complainant from the respondent’s employment is illegal and that the Affidavit of Release /Quitclaim is null and void.

    Accordingly, the respondent is ordered as follows:chanRoblesvirtualLawlibrary

    1) To reinstate the complainant to his former position as radio broadcaster and production manager without loss of seniority rights;cralawlawlibrary

    2) To pay the complainant backwages which as of the date of this decision already amounts to P159,040.00 until his actual reinstatement;cralawlawlibrary

    3) To pay the complainant moral damages in the amount of Php100,000.00 and exemplary damages in the amount of Php100,000.00 and

    4) To pay the complainant attorney’s fees equivalent to 10 percent of the award as stated above.

    The complainant’s claim for regular holiday pay and premiums on holiday pay and rest day are dismissed for lack of sufficient evidence.7ChanRoblesVirtualawlibrary

    Ruling of the NLRC

    RMN appealed to the NLRC, contending that the decision of the Labor Arbiter was premature for being rendered without first issuing an order either setting the case for hearing or declaring the same submitted for decision in violation of Rule V, Section II of the Rules of Procedure of the NLRC, as amended;8 that the quitclaim signed in its favor was valid and binding because it represented a voluntary and reasonable settlement of Michael’s claims; and that Michael was estopped from filing the illegal dismissal case against it.9

    In its decision rendered on November 28, 2003,10 the NLRC found no merit in the contention of RMN that the appealed decision was prematurely rendered. It noted that the constancia dated October 28, 2002, which stated “counsel for respondent appeared and asked for a period of ten (10) days from today within which to file reply and after the lapse of the allotted period, with or without said pleading, case shall be submitted for resolution,” clearly showed that RMN was sufficiently apprised that the case would be decided after the lapse of the 10-day period RMN prayed for regardless of whether it filed its reply or not. It held that the quitclaim was null and void for not being voluntarily executed; modified the decision of the Labor Arbiter in that the amount already received by Michael was to be deducted from the monetary benefits awarded to him; and deleted the awards for moral and exemplary damages.

    RMN moved for reconsideration, but the NLRC denied its motion.11

    Decision of the Court of Appeals

    Consequently, RMN filed with the Court of Appeals (CA) its petition for certiorari,12 submitting that the NLRC thereby committed a grave abuse of its discretion amounting to lack or excess of its jurisdiction.

    On August 31, 2004, however, the CA denied due course to the petition and dismissed it for lack of merit.13

    RMN sought for reconsideration of the resolution of the CA, but its motion for that purpose was similarly denied by the CA.

    Issues

    Hence, this appeal by petition for review on certiorari,14 with RMN raising the following issues, to wit:chanRoblesvirtualLawlibrary

    1. Whether or not the November 12, 2002 decision of the Labor Arbiter was prematurely rendered;cralawlawlibrary

    2. Whether or not the November 12, 2002 decision of the Labor Arbiter was rendered in violation of petitioner’s right to due process;cralawlawlibrary

    3. Whether or not the Affidavit of Release/Quitclaim executed by Michael was valid and binding; and

    4. Whether or not private respondent’s dismissal is legal.15

    Ruling of the Court

    That Michael was illegally dismissed from his employment is beyond question. RMN does not dispute this. Its only submission now is that it was discharged from whatever claims Michael had against it arising from his employment by virtue of the Affidavit of Release/Quitclaim he signed in its favor. Accordingly, the remaining question to resolve is whether the quitclaim was valid and binding.

    This Court recognizes that the issue concerning the validity of the quitclaim was a question of fact that is not within the province of a review on certiorari under Rule 45. However, there is reason to hold that the CA manifestly overlooked certain relevant and undisputed facts that, if properly considered, would justify a different conclusion herein. On that basis, the Court has to delve into the factual issue, and has to review the evidence again to ensure that its ruling on the issue jibes with the evidence on record.16 Its doing so is an acceptable exception to the general rule of non-review of factual matters.17

    The CA was quick to rule that Michael had been coerced into signing the quitclaim. It did so because he had assailed the voluntariness of the execution of the quitclaim. It noted that the fact that Michael had refused to sign the May 14, 2002 letter and thereby indicate his acceptance of the terms of his termination stated therein was proof enough of the quitclaim not being freely signed.18

    The Court finds and considers the CA’s ruling unfounded.

    RMN consistently contended that a series of negotiations between Michael and the management preceded the giving of the settlement pay that they had considered as reasonable.19 Not once did Michael refute this contention. Worth noting is that Michael signed the quitclaim to release RMN from any and all claims that could be due to him by reason of his employment after he receiving the agreed settlement pay of P311,922.00.

    Not all quitclaims are per se invalid or against public policy. A quitclaim is invalid or contrary to public policy only: (1) where there is clear proof that the waiver was wrangled from an unsuspecting or gullible person; or (2) where the terms of settlement are unconscionable on their face. In instances of invalid quitclaims, the law steps in to annul the questionable waiver. Indeed, there are legitimate waivers that represent the voluntary and reasonable settlements of laborers’ claims that should be respected by the Court as the law between the parties. Where the party has voluntarily made the waiver, with a full understanding of its terms as well as its consequences, and the consideration for the quitclaim is credible and reasonable, the transaction must be recognized as a valid and binding undertaking, and may not later be disowned simply because of a change of mind.20 A waiver is essentially contractual.

    In our view, the requisites for the validity of Michael’s quitclaim were satisfied. We explain.

    Firstly, Michael acknowledged in his quitclaim that he had read and thoroughly understood the terms of his quitclaim and signed it of his own volition. Being a radio broadcaster and production manager, he occupied a highly responsible position in the company. It would be implausible to hold, therefore, that he could be easily duped into simply signing away his rights. Besides, the language and content of the quitclaim were clear and uncomplicated such that he could not claim that he did not understand what he was signing.

    Secondly, the settlement pay of P311,922.00 was credible and reasonable considering that Michael did not even assail such amount as unconscionably low, or even state that he was entitled to a higher amount.

    Thirdly, that he was required to sign the quitclaim as a condition to the release of the settlement pay21 did not prove that its execution was coerced. Having agreed to part with a substantial amount of money, RMN took steps to protect its interest and obtain its release from all obligations once it paid Michael his settlement pay, which it did in this case.

    And, lastly, that he signed the quitclaim out of fear of not being able to provide for the needs of his family and for the schooling of his children did not immediately indicate that he had been forced to sign the same.22 Dire necessity should not necessarily be an acceptable ground for annulling the quitclaim, especially because it was not at all shown that he had been forced to execute it. Nor was it even proven that the consideration for the quitclaim was unconscionably low, and that he had been tricked into accepting the consideration.23

    With the quitclaim having been freely and voluntarily signed, RMN was released and absolved from any liability in favor of Michael. Suffice it to say that the quitclaim is ineffective in barring recovery of the full measure of an employee’s rights only when the transaction is shown to be questionable and the consideration is scandalously low and inequitable.24 Such is not true here.

    WHEREFORE, the Court GRANTS the petition for review on certiorari; REVERSES and SETS ASIDE the decision promulgated on August 31, 2004; DECLARES the Affidavit of Release/Quitclaim executed by and between respondent Michael Maximo R. Amurao III and petitioner Radio Mindanao Network, Inc. valid and binding; and DISMISSES the complaint for illegal dismissal of Michael Maximo R. Amurao III.

    No pronouncement on costs of suit.

    SO ORDERED.chanroblesvirtuallawlibrary

    Sereno, C.J., Leonardo-De Castro, Perez, and Perlas-Bernabe, JJ., concur.

    Endnotes:


    1Rollo, pp. 25, 55.

    2 Id. at 25.

    3 Id. at 63, 82.

    4 Id. at 64.

    5 Id. at 65-79.

    6 Id. at 98-109.

    7 Id. at 108-109.

    8 Sec. 2. Nature of Proceedings – the proceedings before the Labor Arbiter shall be non-litiguous in nature. Subject to the requirements of due process, the technicalities of law and procedure and the rules obtaining in the courts of law shall not apply thereto. The Labor Arbiter may avail himself/herself of all reasonable means to ascertain the facts of the controversy speedily, including ocular inspection and examination of well-informed person.

    9Rollo, pp. 110-118.

    10 Id. at 137-144.

    11 Id. at 157-158.

    12 Id. at 159-173.

    13 Id. at 44-52; penned by Associate Justice Aurora Santiago-Lagman, with Associate Justice Portia Aliño-Hormachuelos and Associate Justice Rebecca De Guia-Salvador, concurring.

    14 Id. at 23-38.

    15 Id. at 30.

    16Cajucom VII v. TPI Philippines Cement Corporation, G.R. No. 149090, February 11, 2005, 451 SCRA 70, 78; Cabang v. Basay, G.R. No. 180587, March 20, 2009, 582 SCRA 172, 186.

    17Riosa v. Tobaco La Suerte Corporation, G.R. No. 203786, October 23, 2013, 708 SCRA 655, 662.

    18Rollo, p. 17.

    19 Id. at 59, 86, 112, 169, 202.

    20Coats Manila Bay, Inc. v. Ortega, G.R. No. 172628, February 13, 2009, 579 SCRA 300, 311-312.

    21Rollo, p. 305.

    22 Id.

    23Veloso v. Department of Labor and Employment, G.R. No. 87297, August 5, 1991, 200 SCRA 201, 205.

    24City Government of Makati v. Odeña, G.R. No. 191661, August 13, 2013, 703 SCRA 460, 498, citing Interorient Maritime Enterprises, Inc. v. Remo, G.R. No. 181112, June 29, 2010, 622 SCRA 237, 248.

    G.R. No. 167225, October 22, 2014 - RADIO MINDANAO NETWORK, INC., Petitioner, v. MICHAEL MAXIMO R. AMURAO III, Respondent.


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