Laya, Jr. vs.

Philippine Veterans Bank

G.R. No. 205813
Jan 10, 2018

Facts:
 Alfredo F. Laya, Jr. (Laya) was employed as the Chief Legal Counsel for
Philippine Veterans Bank (PVB) in 2001.
 Laya was informed of his retirement effective July 1, 2007, but he requested
an extension of his tenure, which was denied.
 Laya filed a complaint for illegal dismissal against PVB in the National Labor
Relations Commission (NLRC), but his complaint was dismissed.
 Laya appealed to the Court of Appeals (CA), but the CA upheld the dismissal
of his complaint.
 Laya filed a petition for review on certiorari with the Supreme Court, which
denied his petition.
 Laya filed a second motion for reconsideration, arguing that PVB is a public
instrumentality and that the retirement age for civil servants cannot be
"contracted out."
 The Court accepted the referral of the case by the First Division and ruled that
Laya was not validly retired at age 60.
 The Court found PVB guilty of illegal dismissal and ordered them to pay
backwages, separation pay, and costs of suit.
 The Court clarified that second motions for reconsideration are generally
prohibited but may be allowed in exceptional circumstances.

Issue:
 Whether Laya's second motion for reconsideration should be entertained by
the court.

Ruling:
 The second motion for reconsideration should not have been entertained as it
was filed after the case had already attained finality.
 There is no showing of compelling reasons to relax the rule on immutability of
judgments.

Ratio:
 Granting the second motion for reconsideration would cause irregularity and
reward negligence.
 A judgment becomes final and immutable and cannot be changed, even if
there is a perceived error.

Issue:
 Whether the court can look into the factual findings of the Labor Arbiter and
the National Labor Relations Commission.
 Laya, Jr. vs. Philippine Veterans Bank
G.R. No. 205813
Jan 10, 2018

Ruling:
 In a Rule 45 Petition, only questions of law are at issue and the court is limited
to correcting errors of jurisdiction or abuse of discretion.
 Factual findings of labor officials are accorded respect and finality, especially
when backed by substantial evidence.

Issue:
 Whether Laya knowingly and voluntarily agreed to the retirement program of
the bank.

Ruling:
 Laya, as a lawyer and Chief Legal Counsel, should have been aware of the
provisions of the retirement program and cannot claim ignorance.
 Laya had every opportunity to question the retirement program but did not
express any dissent.
 Therefore, the court affirms the ruling that Laya was not illegally dismissed.