Bogo-Medellin Sugarcane Planters Association v. National Labor Relations Commission

PANGANIBAN, J.:

To justify retrenchment, the employer must prove, among other things, serious business losses, and not just any kind or amount of loss. Furthermore, if the requisites provided in Article 283 of the Labor Code are not fulfilled, a deed of quitclaim and release is unavailing to exculpate an employer from liability for illegal retrenchment. The Case In this special civil action for certiorari filed before this Court, petitioners seek the reversal of the November 12, 1990 Decision1 and the March 4, 1991 Resolution of the National Labor Relations Commission in NLRC NCR Case No. RAB VII-0801-85, both of which affirmed the labor arbiter's Decision finding them liable for illegal dismissal.

Acting on private respondents' amended Complaint for illegal dismissal and unfair labor practice, Executive Labor Arbiter Irenea E. Ceniza rendered a Decision dated May 5, 1989, which disposed as follows:2

WHEREFORE, premises considered, judgment is hereby rendered declaring the [Petitioners] Bogo Medellin Sugar Cane Planters Association and Horacio Franco guilty of unfair labor practice for dismissing the [private respondents] for their union activities; ordering the said [petitioners] to reinstate the [private respondents] to their former position with backwages and other benefits and without loss of seniority rights; ordering the [petitioners] jointly and severally to pay to the [private respondents] their service incentive leave[s], backwages and 13th month from the date of their dismissal until the date of this decision in the following amounts less the amount paid to some [private respondents] as separation/gratuity benefits[:] NAME 13th Month Pay SERVICE INCENTIVE PAY BACK-WAGES SEPARATION PAY/GRATUITY BENEFITS NET 1. BONIFACIO MONTILLA P4,915.24 P820.00 P61,440.00 P12,017.94 P55,157.30 2. JOSE YBAÑEZ, JR. 4,915.24 820.00 61,440.00 4,745.48 62,429.76 3. BERNARDO DELA RAMA 4,915.24 820.00 61,440.00 2,580.84 64,594.40 4. ILDEFONSO CARREDO 4,915.24 820.00 61,440.00 12,991.00 54,184.24 5. FORTUNATO MIGABON, JR. 4,915.24 820.00 61,440.00 - 67,175.24 6. ROSETO CANALES 4,915.24 820.00 61,440.00 - 67,175.24 7. HERACLEO MEGABON 4,915.24 820.00 61,440.00 - 67,175.24