Soriano v. Philippine Long Distance Telephone Company
REITERATIONFacts
The Antecedents: Petitioner Francisco Soriano, Jr. was employed by Philippine Long Distance Telephone Company, Inc. (PLDT) as a Switchman Helper in 1980, and was later promoted to Switchman. In November 1995, PLDT implemented a company-wide redundancy program, citing technological changes, process improvements, and automation as reasons for reducing its workforce. Consequently, on August 16, 1996, PLDT terminated the employment of petitioner and three other employees, informing them that their positions were deemed redundant. The affected employees received separation pay and executed a Release, Receipt, and Quitclaim, albeit with a note of "Under Protest" beside their signatures. Procedural History: Following their dismissal, petitioner and the other affected employees filed a joint complaint for illegal dismissal against PLDT. The Labor Arbiter dismissed the complaint, finding that PLDT's redundancy program was implemented in good faith and complied with legal requirements. This decision was affirmed by the National Labor Relations Commission (NLRC). The employees then filed a Petition for Certiorari with the Court of Appeals, which also dismissed the petition, finding no grave abuse of discretion on the part of the NLRC. Subsequently, the employees filed a Petition for Review on Certiorari with the Supreme Court. Initially, the petition was denied due to a defect in the verification and certificate of non-forum shopping. However, upon motion for reconsideration, the petition was reinstated solely for petitioner Soriano, Jr., with the other petitioners excluded. The Petition: Petitioner Francisco Soriano, Jr. seeks to set aside the decision of the Court of Appeals, raising three issues: (1) whether the Court of Appeals erred in refusing to review the factual findings of the NLRC; (2) whether there was substantial evidence to support the NLRC's finding of lawful termination due to redundancy; and (3) whether his acceptance of separation benefits constitutes a waiver of his right to question the dismissal. The petition argues that the Court of Appeals should have reviewed the factual findings of the NLRC, especially when substantial evidence might be lacking. Petitioner contends that the redundancy was not sufficiently proven and that PLDT's actions, such as hiring contractual employees and denying his transfer requests, contradict the claim of redundancy. Furthermore, he asserts that his acceptance of separation pay was under duress due to personal circumstances and did not signify a waiver of his right to challenge the dismissal.
Issue(s)
Whether the Court of Appeals erred in refusing to review the factual findings of the NLRC. Whether the NLRC's finding of lawful termination due to redundancy is supported by substantial evidence. Whether the petitioner's acceptance of separation benefits amounts to a waiver of his right to question the validity of his dismissal.
Ruling
The petition is DENIED. The Decision and Resolution of the Court of Appeals are AFFIRMED.
Ratio Decidendi
On the issue of the Court of Appeals reviewing NLRC's factual findings: The Supreme Court reiterated that in certiorari proceedings under Rule 65, the appellate court's review is limited to determining if the NLRC acted without or in excess of jurisdiction or with grave abuse of discretion. While an exception exists where NLRC's findings are not supported by substantial evidence, in this case, the Court of Appeals correctly limited its review. The factual findings of the Labor Arbiter, NLRC, and Court of Appeals were all anchored on substantial evidence, negating any claim of grave abuse of discretion. The Court emphasized that its jurisdiction under Rule 45 is limited to reviewing errors of law, not fact, unless specific exceptions apply, none of which were present here. On the issue of lawful termination due to redundancy: The Court found that PLDT sufficiently established the existence of redundancy. The company implemented a redundancy program due to technological advancements, specifically the conversion of electro-mechanical switches to modern digital switches, which rendered the manual operation and maintenance of Electronic Mechanical Devices (EMDs) by Switchmen obsolete. PLDT submitted documentary evidence, including notices to the DOLE, termination letters, proof of separation pay, and affidavits explaining the redundancy program, which petitioner failed to refute. The Court also found the testimony of Roberto D. Lazam, a Senior Manager, competent and credible, as he was a licensed electrical engineer with extensive experience in switching systems and had trained Switchmen. The Court concluded that the position of Switchman had become redundant due to the adoption of high-technology equipment that could perform the functions of several Switchmen with minimal human intervention. On the issue of acceptance of separation benefits as waiver: The Court held that while deeds of release, waiver, or quitclaims are generally viewed with disfavor and can be set aside if tainted with fraud, deceit, or coercion, they can be considered valid and binding if voluntarily executed with full understanding and supported by credible and reasonable consideration. Petitioner, being educated and having held responsible positions, was presumed to understand the consequences of signing the "Receipt, Release, and Quitclaim." His admission that he signed voluntarily, albeit compelled by personal circumstances (parent's illness), rather than by PLDT, indicated no deceit or coercion. The consideration received (separation pay exceeding the legal requirement) was credible and reasonable. Therefore, the quitclaim was considered a legal and binding undertaking, precluding petitioner from assailing the validity of his dismissal and preventing unjust enrichment.
Main Doctrine
The acceptance of separation pay, coupled with a signed "Receipt, Release, and Quitclaim" executed voluntarily and with full understanding of its consequences, and supported by a credible and reasonable consideration, constitutes a valid and binding settlement that precludes an employee from assailing the legality of their dismissal, provided the employer complied with the legal requirements for redundancy.