This case has been cited 6 times or more.
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2015-10-14 |
PERALTA, J. |
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| Redundancy exists when the service capability of the workforce is in excess of what is reasonably needed to meet the demands of the enterprise.[16] A redundant position is one rendered superfluous by any number of factors, such as over hiring of workers, decreased volume of business, dropping of a particular product line previously manufactured by the company, or phasing-out of a service activity previously undertaken by the business.[17] Under these factors, the employer has no legal obligation to keep in its payroll more employees than are necessary for the operation of its business.[18] Even if a business is doing well, an employer can still validly dismiss an employee from the service due to redundancy if that employee's position has already become in excess of what the employer's enterprise requires.[19] | |||||
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2014-10-22 |
BERSAMIN, J. |
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| 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. | |||||
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2012-11-21 |
PEREZ, J. |
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| Morales, finally, argues that the CA erred in upholding the validity of the 10 November 2003 Release, Waiver and Quitclaim which he supposedly signed out dire economic necessity. While "it may be accepted as ground to annul [a] quitclaim if the consideration is unconscionably low and the employee was tricked into accepting it, [dire necessity is not, however,] an acceptable ground for annulling the release when it is not shown that the employee has been forced to execute it."[45] Not having sufficiently proved that he was forced to sign said Release, Waiver and Quitclaim, Morales cannot expediently argue that quitclaims are looked upon with disfavor and considered ineffective to bar claims for the full measure of a worker's legal rights. This Court has held that not all quitclaims are per se invalid or against public policy, except (1) where there is clear proof that the waiver was wangled from an unsuspecting or gullible person, or (2) where the terms of settlement are unconscionable on their face.[46] These two instances are not present in this case. | |||||
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2012-01-18 |
REYES, J. |
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| That the petitioner was all set to return to his hometown and was in dire need of money would likewise not qualify as undue pressure sufficient to invalidate the quitclaim. "Dire necessity" may be an acceptable ground to annul quitclaims if the consideration is unconscionably low and the employee was tricked into accepting it, but is not an acceptable ground for annulling the release when it is not shown that the employee has been forced to execute it.[30] While it is our duty to prevent the exploitation of employees, it also behooves us to protect the sanctity of contracts that do not contravene our laws.[31] | |||||
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2011-06-15 |
PEREZ, J. |
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| In its assailed 16 November 2007 decision in CA-G.R. CEB-SP No. 02232, the CA's then Eighteenth Division brushed aside said deeds of waiver, release and quitclaim on the ground, among other matters, that the same only covered the employees' separation pay and retirement benefits but did not extend to the benefits which had accrued in their favor under the imposed CBA; and, that to be valid, the waiver "should be couched in clear and unequivocal terms leaving no doubt as to the intention of those giving up a right or a benefit that legally pertains to them." [61] In so doing, however, the CA's Eighteenth Division egregiously disregarded the clear intent on the part of the employees who executed said deeds of waiver, release and quitclaim to relinquish all present and future claims arising out of their employment with GMC. Although generally looked upon with disfavor, [62] it cannot be gainsaid that legitimate waivers that represent a voluntary and reasonable settlement of laborers' claims should be so respected by the Court as the law between the parties. [63] It is only where there is clear proof that the waiver was wangled from an unsuspecting or gullible person, or the terms of settlement are unconscionable on its face, that the law will step in to annul the questionable transaction. [64] The absence of showing of these factors in the case at bench impels us to uphold the validity of said deeds of waiver, release and quitclaim and, to exclude the employees who executed the same from those still entitled to the benefits under the imposed CBA both before and after the remaining term of the original CBA. The waiver was all inclusive. There was not even a hint of a limitation of coverage. | |||||
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2009-08-14 |
CARPIO, J. |
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| The Court recognizes that a host of relevant factors comes into play in determining who among the employees should be retained or separated.[23] Among the accepted criteria in implementing a redundancy program are: (1) preferred status; (2) efficiency; and (3) seniority.[24] | |||||