Goodyear Phils., Inc. v. Angus !" $%&'()'* "+!, - .'/ 01234//%5 67 8'34*'('93 : 0%//';34%9 %< )%3= *'34*'('93 )'9'<432 19> 2'?1*134%9 ?1@ ABC% 1*' (D3D1//@ 'E;/D24&'F !"#$%&$' )*+ ,-$."/0% 123 PETITIONERS: Goodyear Philippines, Inc.; Remegio M. Ramos RESPONDENT: Marina L. Angus SUMMARY: When Goodyear experienced economic reversals, it resorted to the retrenchment of certain employees in order to continue its operations. One such employee is Marina, and she was granted an early retirement benefit, as per company practice. However, she claimed entitled to separation pay in addition to the retirement benefits already received. DOCTRINE: Retirement benefits and separation separation pay are not mutually exclusive. Retirement benefits benefits are a form of reward for an employee’s loyalty and service to an employer, whereas separation pay is that amount which an employee receives at the time of his severance from employment, designed to provide the em ployee with the wherewithal during the period that he is looking for another employment
FACTS: 1. 19 November 1966: Marina was employed by Goodyear on Novemb er 19, 1966 as the secretary to the Manager of Quality and Technology.
2.
Goodyear experienced economic reversals. To continue its operations, it resorted to retrenchment.
3.
18 September 2001: Marina received a letter from Remegio Ramos, HR Director, stating that management considered her position redundant and no longer necessary and is to be abolished on the same day, with her services to be terminated after a month. Per company practice, the company only granted her an early retirement benefit.
4.
Marina claims that she is entitled to separation pay in addition to retirement benefits.
5.
Goodyear points to a provision in their CBA stating that the availment of retirement benefits therein shall exclude entitlement to any separation pay, termination pay, redundancy pay, retrenchment pay, or any other severance pay.
6.
The parties finally agreed that an employee shall be entitled to the higher of either benefit. However, Marina later contested this.
ISSUE: WON Marina is entitled to both retirement benefits and separation pay. RATIO: Labor Law; Retireme nt Benefits; Separatio n Pay; Retirement Retirem ent benefits and separation pay are not mutually exclusive. —It —It is worthy to mention at this point that retirement benefits and separation pay are not mutually exclusive. Retirement benefits are a form of reward for an employee’s loyalty and service to an employer and are earned under existing laws, CBAs, employment contracts and company policies. On the other hand, separation pay is that amount which an employee receives at the time of his severance from employment, designed to provide the employee with the wherewithal during the period that he is looking for another employment and is recoverable only in
instances enumerated under Articles 283 and 284 of the Labor Code or in illegal dismissal cases when reinstatement is not feasible. In the case at bar, Article 283 clearly entitles Angus to separation pay apart from the retirement benefits she received from petitioners.
