Quintin Beltran v. AMA Computer College, G.R. No. 223792, April 3, 2019.

The case of Beltran versus AMA Computer College Binan deals with the benefit that had ripened into a company practice.
Quintin Beltran was hired in June 1990 by AMA education system or AMA as a mathematics instructor, eight years later he was
promoted as its school register and was able to work as such until April 1999, while serving a school registrar, he was promoted
as school administrator slash chief operations officer of AMA College in Binan Laguna in January 1999. Quentin alleged that
sometime in 2008 he applied for early retirement relying on a long-standing policy of AMA in granting early retirement benefits
to its employees. While the set application for early retirement was being processed, Beltran was requested to continue his
employment until after the enrollment period later he was informed of the approval of his application and the processing of the
payment of his benefits.

On June 3, 2008, Beltran was compelled to leave immediately for the USA to avoid the cancellation of his visa as a permanent
resident.

While on vacation in the Philippines, Beltran filed a complaint for payment of retirement benefits/ separation pay against AMA
and AMA contended that Beltran’s request in 2008 for early retirement was disapproved, and that before the denial could be
communicated to him, Beltran had already left the country without submitting a resignation letter and following the standard
company policy on proper turnover of work and accomplishment of clearance.

AMA added that it was willing and ready to release the pending salary and 13th month pay in the total amount of 28,046.34
less the unliquidated amount for the 2008 graduation. Beltran retorted that he underwent an exit interview clearance
procedures and turnover of work accountabilities. Beltran then claimed that his basic monthly salary was 51,310 pesos and not
25,000 pesos he also denied that he received unliquidated budget for the 2008 graduation.

Lastly, Beltran argued that while it had no written retirement plan, AMA had a longstanding practice of granting early
retirement separation pay or cash gift or benefit to those who have not reached the compulsory retirement age or mandatory
20 year service requirement.

ISSUE:

WON Beltran entitled to retirement benefits

RATIO: YES

Supreme Court ruled that Quentin was entitled to retirement benefits from AMA. The court stated that Article 302 of the Labor
Code of the Philippines provides for the voluntary retirement age of 60 years old and the mandatory retirement age of 65 years
old. In addition to the age requirements, the employee must have served at least five years in the company. Statutory
retirement benefit expects that 1/2-month salary for every year of service or a fraction thereof. The employer, however, is free
to grant other retirement benefits and impose different age or service requirements provided that the benefits shall not be
lesser than those provided in article 302.

The court then discussed article 100 of the Labor Code of the Philippines. According to the court the said article expressly
prohibits the elimination or reduction of benefits received by employees. However, the basis for the grant of said benefit must
be shown through an express policy written contract or an unwritten policy that has ripened into a company practice.

To be considered a practice, it must be consistently and deliberately made by the employer over a significant period of time.
The court added that it has not defined what constitutes a significant period of time.

Jurisprudence explains that the matter is decided according to the peculiar facts and circumstances of each case. The common
denominator of which is the regularity and deliberateness of the grant of benefits over a significant period of time.

In the present case, the court found that Beltran was able to prove through substantial evidence the existence of an established
company practice of granting early retirement to its employees have rendered at least 10 years of service regardless of age,
specifically, the court admitted the affidavits of Salvation and Elsa, two former AMA employees who both attested in their
separate affidavits that they were former employees of AMA and they were granted retirement benefits.

The court noted that although they did not personally confirm the award of their early retirement, the affidavits showed that
they occupied managerial positions and were privy to the policies of the school and to the movements or retirement of their
subordinate personnel.

Nonetheless, the court found that affidavits revealed the following:

#1 Salvation was AMA school director in Quezon city while Elsa was its registrar of the basic education department also in
Quezon City

#2 Salvation worked for AMA for 11 years and Elsa was with AMA for 18 years

#3 AMA granted an early retirement program to its employees who had rendered at least ten years of service

#4 both received early retirement benefits of one month salary for every year of service pursuant to the early retirement
program of AMA

#5 8 (eight) other employees were able to avail of the early retirement program.

On the other hand, the court also found that AMA denied that it had any existing early retirement policy, and the grant of
Salvation and Elsa's requests were isolated cases. However, the court stressed that AMA did not submit controverting evidence
to refute Salvation and Elsa’s statements in their affidavits as to the grant of early retirement benefits to its other employees.
Notably AMA did not explain why Salvation and Elsa’s requests for early retirement were granted but Beltran’s request was
denied.

The court held that Beltran substantially proved that AMA had the consistent company practice of granting early retirement to
its employees who have rendered at least 10 years of service for the court Beltran was entitled to retirement benefits.