Republic of the
SUPREME COURT
SECOND DIVISION
|
ALFREDO
A. MENDROS, JR.,
Petitioner,
- versus - MITSUBISHI MOTORS PHILS.
CORPORATION (MMPC), Respondent. |
|
G.R. No. 169780 Present: QUISUMBING,
J., Chairperson, CARPIO MORALES, TINGA, VELASCO,
JR., and BRION,
JJ. Promulgated: February
16, 2009 |
x-----------------------------------------------------------------------------------------x
D E C I S I O N
VELASCO, JR., J.:
This is
an appeal, via a petition for review under Rule 45, from the Decision[1]
dated November 18, 2004 of the Court of Appeals (CA) in CA-G.R. SP No. 84790
which reversed and set aside the Resolutions dated September 23, 2002[2]
and January 30, 2004 of the National Labor Relations Commission (NLRC) in NLRC
NCR CA No. 028205-01, and reinstated the February 27, 2001 Decision[3] of
the Labor Arbiter in NLRC Case No. RAB-IV-9-11454-99-R.
From
the petition and its annexes, the respondent’s comment thereto, and the
parties’ respective memoranda, the Court gathers the following facts:
In
April 1994, respondent Mitsubishi Motors Philippines Corporation (MMPC) hired
petitioner Alfredo A. Mendros, Jr. as regular body prepman, later promoting him
as assembler major in the company’s manufacturing division.
Due to the severe drastic slump of its vehicle
sales brought about by the financial crisis that hit the country and other
Asian economies in 1997, MMPC, per its audited financial statements, sustained
a financial loss of PhP 470 million in 1997 and PhP 771 million in 1998. In the
face of these setbacks and in a bid to cushion the impact of its business
reversals and continue operations, MMPC implemented various cost-cutting
measures, such as but not limited to: cost reduction on the use office supplies
and energy, curtailment of representation and travel expenses,
employment-hiring freeze, separation of casuals and trainees, manpower services
(guards and janitorial services) reduction, intermittent plant shutdowns, and
reduced work week for managerial and other monthly-salaried personnel.
In
February 1998, MMPC finally instituted the first stage of its retrenchment
program affecting around 531 hourly manufacturing employees, a step which later
proved not adequate enough to stem business reverses. Hence, after holding special labor-management
meetings with the hourly union, MMPC launched a temporary lay-off program to
cover some 170 hourly employees. This batch included Alfredo who, sometime in
January 1999, received a letter dated
In the
interim, MMPC updated the temporarily-suspended Alfredo, et al. of its business
condition.
As
later events unfolded, the temporary lay-off move was still not enough to avert
further losses. In fact, the market situation even slid down. This development
impelled MMPC to embark on another retrenchment program affecting the hourly
employees. Accordingly, on
It may
be mentioned at this juncture that the July 1999 retrenchment of 170 hourly
employees was preceded by the retrenchment of monthly-salaried MMPC employees.
In effect, therefore, the lay-off of the 170 employees was the second
retrenchment implemented by MMPC in 1999 and the third since 1998.
On
In
September 1999, Alfredo filed a case for illegal dismissal and damages before
the NLRC’s Regional Arbitration Branch No. IV, docketed as NLRC Case No.
RAB-IV-9-11454-99-R.
The Ruling of the Labor Arbiter
Conciliation
efforts having failed, hearings were held, followed by a directive for the
submission of position papers. In its position paper, MMPC defined the criteria
used in considering employees for retrenchment. And among the documents it
filed together with its pleadings were its 1997-1996 and 1998-1997 Financial Statements prepared by SGV
& Co. On
From
the arbiter’s ruling, Alfredo appealed to the NLRC, its appeal docketed as NLRC NCR CA No. 028205-01.
The
Ruling of the NLRC
The
NLRC saw things differently. By Resolution dated
IN VIEW
THEREOF, the judgment appealed from is hereby REVERSED and SET ASIDE and a new
one ENTERED declaring the temporary lay-off / retrenchment as illegal and
ordering the respondent [MMPC] to immediately reinstate the complainant
[Alfredo] to his former position without loss of seniority rights and other
benefits accorded the regular employees pursuant to their Collective Bargaining
Agreement, with full backwages which as of September 16, 2002 amounts to
P447,349.99.
A ten percent
(10%) attorney’s fee is likewise adjudged.
The computation
submitted by the Computation and Examination Unit is hereby adopted as Annex
“A” and an integral part hereof.
SO ORDERED.[5]
While
it agreed with the labor arbiter’s holding on MMPC’s compliance with the substantive and
procedural requirements for retrenchment, the NLRC deemed the merit rating
system adopted by MMPC as additional and dominant criterion for retrenchment to
be erroneous and arbitrary, being against the parties’ then prevailing
Collective Bargaining Agreement (CBA). The CBA, according to the NLRC, listed
only “seniority” and “needs of the company” as
determinative factors in the selection of who shall be laid off. To the NLRC, MMPC’s arbitrary way and the
fact that it did not notify Alfredo beforehand of the additional criterion, not
to mention the findings of the merit valuation, vitiated the retrenchment
proceedings.
By
Resolution of
The Ruling of the CA
On November 18, 2004, the appellate court
rendered the appealed Decision finding for MMPC, the dispositive portion of
which reads, as follows:
WHEREFORE,
finding merit in the petition, We hereby GRANT the same. The assailed Resolutions of public respondent
National Labor Relations Commission (NLRC) are hereby REVERSED and SET ASIDE
and the Decision of the Labor Arbiter dated
SO ORDERED.[6]
In
reinstating the labor arbiter’s ruling and setting aside that of the NLRC, the
appellate court addressed two central issues: first, whether MMPC used fair and reasonable criteria in
ascertaining who would be retrenched; and second,
whether MMPC should have had furnished Alfredo copies of its AFS and the
findings of its merit evaluation. It resolved the first issue in the
affirmative and the second in the negative.
Following
the denial of his motion for reconsideration, per the CA’s resolution of
The Issues
Petitioner
Alfredo, through his Memorandum, raises the following issues for our
consideration:
I.
WHETHER OR NOT PETITIONER’S RETRENCHMENT
WAS ILLEGAL.
A.
WHETHER OR NOT MERIT RATING AND RANKING
ARE PART OF THE CBA MANDATED CRITERIA IN DETERMINING THE REGULAR EMPLOYEE TO BE
RETRENCHED.
B.
WHETHER OR NOT [MMPC] CAN VALIDLY ADOPT
MERIT RATING AND RANKING AS PART OF THE CRITERIA IN DETERMINING THE REGULAR EMPLOYEE
TO BE RETRENCHED.
C.
WHETHER OR NOT [MMPC] SHOULD HAVE
DISCLOSED IN ITS NOTICE OF RETRENCHMENT TO PETITIONER, THE LATTER’S LOW MERIT
RATING AND RANKING AS THE PRINCIPAL REASON FOR HIS RETRENCHMENT AND FURNISHED
PETITIONER WITH THE CORRESPONDING [AFS] TO SUBSTANTIATE ITS CLAIM OF LOSSES.
D.
WHETHER OR NOT PETITIONER’S RETRENCHMENT
CAN BE DEEMED VALID JUST BECAUSE [MMPC’S] EARLIER RETRENCHMENT OF HIS OTHER
CO-EMPLOYEES HAD BEEN ADJUDGED BY OUR COURTS TO BE VALID.
II.
WHETHER OR NOT THE [CA] CORRECTLY FOUND
THAT THE NLRC COMMITTED GRAVE ABUSE OF DISCRETION AMOUNTING TO LACK OR EXCESS
OF JURISDICTION IN REVERSING AND SETTING ASIDE THE DECISION OF LABOR ARBITER
PORTILLO AND ORDERING THE REINSTATEMENT x x x.[7]
The
fundamental issues tendered actually boil down to the legality and/or validity of
Alfredo’s temporary lay-off and eventual retrenchment.
The
Court’s Ruling
We deny
the petition.
The
right of management to retrench or to lay-off workers to meet clear and
continuing economic threats or during periods of economic recession to prevent
losses is recognized[8] by
Article 283 of the Labor Code, as amended, partly providing:
Art. 283. Closure of establishment and reduction of
personnel.––The employer may also terminate the employment of any employee
due to x x x retrenchment to prevent
losses or the closing or cessation of operations of the establishment x x x
by serving a written notice on the worker and the [DOLE] at least one month
before the intended date thereof. x x x In case of retrenchment to prevent
losses, the separation pay shall be equivalent to one (1) month pay or at least
one-half month pay for every year of service whichever is higher. x x x
(Emphasis ours.)
Decisional law teaches that the
requirements for a valid retrenchment are: (1) that the retrenchment is
reasonably necessary and likely to prevent business losses which, if already
incurred, are not merely de minimis,
but substantial, serious, and real, or only if expected, are reasonably
imminent as perceived objectively and in good faith by the employer; (2) that
the employer serves written notice both to the employees concerned and the DOLE
at least a month before the intended date of retrenchment; (3) that the
employer pays the retrenched employee separation pay in an amount prescribed by
the Code; (4) that the employer exercises its prerogative to retrench in good
faith; and (5) that it uses fair and reasonable criteria in ascertaining who
would be retrenched or retained.[9]
In F.F. Marine Corporation v. National Labor Relations Commission,
the Court expounded on the concept, requisites, and justification of
retrenchment in the following wise:
Retrenchment is the termination of
employment initiated by the employer through no fault of the employees x x x
resorted to by management during periods of business recession, industrial
depression, or seasonal fluctuations or during lulls occasioned by lack of
orders, shortage of materials, conversion of the plant for a new production
program or the introduction of new methods or more efficient machinery, or of
automation. Retrenchment is a valid management
prerogative. It is, however, subject to
faithful compliance with the substantive and procedural requirements laid down
by law and jurisprudence.
There are three (3) basic requisites for a valid retrenchment to exist, to wit: (a) the retrenchment
is necessary to prevent losses and such losses are proven; (b) written notice
to the employees and to the DOLE at least one (1) month prior to the intended
date of retrenchment; and (c) payment of separation pay x x
x.
Jurisprudential standards to justify retrenchment have
been reiterated by this Court in a long line of cases to forestall management
abuse of this prerogative, viz:
. . . . Firstly, the losses expected should be substantial and not
merely de minimis in extent. If the loss purportedly sought to be
forestalled by retrenchment is clearly shown to be
insubstantial and inconsequential in character, the bonafide nature of
the retrenchment would appear to be seriously in question. Secondly,
the substantial loss apprehended must be reasonably imminent, as such imminence
can be perceived objectively and in good faith by the employer. There should, in other words, be a certain
degree of urgency for the retrenchment, which is after all a
drastic recourse with serious consequences x x x. Because of the consequential
nature of retrenchment, it must, thirdly, be reasonably
necessary and likely to effectively prevent the expected losses. The employer
should have taken other measures prior or parallel to retrenchment
to forestall losses, i.e., cut other costs than labor costs. An employer who, for instance, lays off
substantial numbers of workers while continuing to dispense fat executive
bonuses and perquisites or so-called “golden parachutes”, can scarcely claim to
be retrenching in good faith to avoid losses.
To impart operational meaning to the constitutional policy of providing
“full protection” to labor, the employer’s prerogative to bring down
labor costs by retrenching must be exercised essentially as a measure of last
resort, after less drastic means—e.g., reduction of both
management and rank-and-file bonuses and salaries, going on reduced time, x x x
costs, etc.—have been tried and found wanting.
Lastly, x x x alleged losses if already realized, and the expected
imminent losses sought to be forestalled, must be proved by sufficient and
convincing evidence. The reason
for requiring this quantum of proof is readily apparent: any less exacting
standard of proof would render too easy the abuse of this ground for
termination of services of employees.[10] (Emphasis supplied.)
Given
the foregoing legal perspective, the resolution of the basic core issue should
be in the affirmative. We are one with the appellate court in finding that the
essential requisites for a valid retrenchment laid down by law and
jurisprudence are obtaining.
First, there
can hardly be any dispute that MMPC suffered substantial and heavy losses in FY
1997 and continued to bleed in 1998. Even the NLRC conceded this reality. To be
precise, MMPC, as duly shown in its AFS for those fiscal years,[11] incurred an aggregate loss of PhP 1.242 billion
for its two-year operation. To be sure, the AFS in question and necessarily the
figures appearing therein cannot be assailed as self-serving, as these
documents were prepared and signed by SGV & Co., a firm of reputable
independent external auditors. Any suggestion that a billion peso plus loss is de minimis in extent has to be dismissed
for sheer absurdity.
Alfredo’s lament about not being
furnished a copy of the 1997-1996 and 1998-1997 AFS and other financial
documents, as well as the finding of the merit evaluation rating, at the time
he was notified of his lay-off cannot be accorded tenability. The CA explained succinctly
why:
x x x There is no law or rule that requires an
employer to furnish an employee to be retrenched copies of its [AFS] and other
documents (e.g. finding of its merit evaluation). The law only requires that
the employer serve a written notice of the retrenchment on the employee concerned and the [DOLE] at least
one (1) month before the intended date thereof. [Alfredo’s] contention that he
should have been notified of his merit rating in order for him to seek a
clarification and even a reconsideration of the same from [MMPC] is without
merit. The appropriate forum for an employee to contest the reality or good
faith character of the retrenchment asserted as ground for dismissal from
employment is before the [DOLE].[12] (Citation
omitted.)
Second,
Alfredo cannot plausibly feign ignorance that MMPC was in dire straights in
1997 and 1998. Neither can he impugn the bona
fides of MMPC’s retrenchment strategy. Recall that MMPC, while experiencing
business reverses, implemented expense-cutting measures starting from reduction
on the use of utilities and office supplies, curtailing of representation and
travel expenses and deferring the implementation of set projects and programs.
It froze hiring and letting its casual employees and trainees go. And as the records
show, a reduced work week was set in place for managerial employees who,
doubtless at management’s behest, agreed to a 5% salary cut. In fine, the
retrenchment of Alfredo’s batch on
Third, it
bears to state that the aforequoted Art. 283 of the Code uses the phrase “retrenchment
to prevent losses.” The phrase necessarily implies that retrenchment may be
effected even in the event only of imminent, impending, or expected losses.[13]
The employer need not wait for substantial losses to materialize before
exercising ultimate and drastic option to prevent such losses. In the case at
bench, MMPC was already financially hemorrhaging before finally resorting to
retrenchment.
Fourth, MMPC
had complied with the prior written notice and separation pay requirements.
Alfredo was duly apprised of his fate a
month before the effectivity of his
retrenchment, and the DOLE duly informed likewise a month before the
Finally, as the Court sees it, the
merit rating system MMPC adopted as one of the criteria for selecting who are
to be eased out was fair and reasonable under the premises. Alfredo, of course,
latches the success of his cause principally on the propriety of the criteria
thus adopted, faulting the CA in the manner it construed Art. V of the CBA then
governing the employer-employee relationship between MMPC and the hourly employees.
For
clarity, we reproduce the pertinent provisions of Art. V of the CBA on lay-off
and other personnel/employee movements, specifically Sections 1 to 6, to wit:
ARTICLE V
PROMOTIONS, TRANSFERS,
LAY-OFFS
AND RECALLS
SECTION 1.
FACTORS TO BE FOLLOWED IN EMPLOYEE MOVEMENTS –– In the exercise of
customary functions of Management as regards promotions, transfer, lay-off and recall, the COMPANY shall
be guided by the following: Seniority,
Efficiency and Attitude, Job Knowledge and Potential, and Attendance and
the COMPANY shall exercise just and
fair evaluation of such factors. It is understood that this provision
is applicable only to members of the bargaining unit and to movements within
the bargaining unit.
SECTION 2. In
the application of the foregoing criteria, the following definition shall be
observed
(a) SENIORITY; Defined:
1. Department
Seniority — starts from the day of permanent assignment to a Production
Department or Non-Production Department.
2. Job Security
— starts from the day of permanent assignment to the job in Production or
Non-Production Department.
3. Corporate
Seniority — starts as of the first day of the probationary period of a regular
employee.
(b) EFFICIENCY
AND ATTITUDE — is defined as follows:
1. Ability to perform good work in
accordance with COMPANY standards.
2. Ability to cooperate with supervisory
staff and fellow employees.
3. Readiness to accept supervisor’s
instructions and to perform them properly.
4. Compliance with COMPANY policies, rules
and regulations.
5. Physical fitness.
(c) JOB
KNOWLEDGE AND POTENTIAL — as defined as follows:
1. Knowledge and ability to perform the job
in accordance with COMPANY standards.
2. Possession of broad knowledge of various
types of work which will assure satisfactory performance of other work assignments.
3. Adaptability to learn new work
procedures.
4. Ability to improve work methods.
(d) ATTENDANCE is defined as follows:
Promptness in reporting to work; in other words,
prompt observance of time signals, scheduled starting time, morning and
afternoon breaktime, lunch time and quitting time. x x x
SECTION 3.
PROMOTIONS — Promotion is the movement of a qualified employee to a
higher job classification or lateral movement to a higher level within the same
job classification and shall entitle such employee to the appropriate wage
range applicable to the new position or job level.
x x x x
SECTION 4.
TRANSFERS –– Transfers are considered movements from one job assignment
to another, either on a temporary or permanent basis. In all cases of transfers, whether temporary
or permanent, the COMPANY will be guided
by the factors mentioned in Section 1 above.
x x x x
SECTION 5.
LAY-OFFS – Lay-Offs shall be guided by the following factors:
(a) TEMPORARY
LAY-OFF — is the adjustment or reduction in work force due to x x x and other
causes that will necessitate the temporary reduction of work force.
(b) PERMANENT
LAY-OFF — is a reduction in work force due to decrease in COMPANY business.
(c) LAY-OFF
PROCEDURE –– in case of lay-off whether in the Production or Non-Production
Departments, all temporary, casual and probationary employees will be laid-off
first. Regular employees will be
laid-off taking into consideration corporate seniority (last-in,
first-out) and the needs of the COMPANY.
(d) No employee
will be upgraded due to lay-off.
SECTION 6.
RECALLS TO WORK –– When there is a need to increase the work force after
a lay-off, preference shall be given to retrenched employees on the basis of
corporate seniority and provided they are qualified for the job opening. (Emphasis
ours.)
Alfredo argues that since Art. V, Sec
5(c) of the CBA provides for only two factors, i.e., (1) seniority (last-in,
first-out) and (2) the needs of the company, to be considered in retrenching
MMPC employees, the company is bereft of authority to arbitrarily impose other
factors or criteria in effecting his retrenchment.
We are not persuaded.
Evaluation Method Used by MMPC in Determining the
Employees to be Retrenched Is in Accord
with the CBA
It is well-entrenched that if the terms
of a contract are clear and leave no doubt as to the
intention of the contracting parties, the literal meaning of the stipulations
shall control.[15] Courts,
in appropriate cases, will intervene only when the terms of the contract are
ambiguous or uncertain and only to construe them to seek the real intent of the
parties and not to alter them.[16]
Just as
settled is the rule that contracts should be so construed as to harmonize and
give effect to the different provisions of these contracts.[17]
Under Art. 1374[18] of the
Civil Code, contracts cannot be construed by parts; stipulations and clauses must be considered in
relation to one another to give effect to the whole. The legal effect of a contract is not
determined alone by any particular provision disconnected from all others, but
from the whole read together.[19]
Following the above rules, the
aforequoted Secs. 1 and 2 should be read as qualifying the factors mentioned in
the succeeding Sec. 5(c). It may be that
Sec. 5(c) mentions only “seniority” and “needs of the company” as factors to be
considered in the retrenchment selection process. But these twin factors cannot plausibly be
given exclusivity for Sec. 1 is clear in that the factors or criteria provided
therein, i.e., seniority,
efficiency and attitude, job knowledge and potential, and attendance, are to be
considered in the exercise of management as regards lay-off, among other
personnel movements. Sec. 5 ought not to
be treated alone, isolated from kindred provisions.
Sec. 1, Art. V of the CBA, to reiterate,
allows MMPC, in the exercise of its customary management functions and
prerogatives on matters of promotions, transfer, lay-off, and recall, to
consider as guiding norms the following factors or criteria: “Seniority,
Efficiency and Attitude, Job Knowledge and Potential, and Attendance.” And to
complement this prerogative, the company, in the same section, is given the
discretion to “exercise just and fair evaluation of such factors,” meaning that
the company is accorded a reasonable latitude to assign a corresponding weight
to each factor. On the other hand, Sec.
2 merely defines or describes the factors or criteria mentioned in Sec. 1.
As couched, Sec. 1 is explicit in
providing the criteria or factors for all employee movements. A reading of the other provisos would show
the following: Sec. 3 on PROMOTIONS does
not specifically mention any criterion or factor, logically implying that the
factors expressly mentioned in Sec. 1 shall apply to promotional appointments;
Sec. 4 on TRANSFERS, on the other hand, provides that the factors mentioned in
Sec. 1 apply; Sec. 5 on LAY-OFFS provides the factors of seniority and needs of
the company; while Sec. 6 on RECALLS TO WORK provides the sole factor of
seniority. Given the way the provisions
were couched relative to Sec. 1, it is clear to our mind, despite the seeming
limited factors provided in Secs. 5 and 6, that the factors or criteria
provided in Sec. 1, as defined in Sec. 2,
encompass and apply to all employee movements.
Alfredo’s posture that the Sec. 1
criteria are to be viewed as a general standard and must be made to yield to
those specifically provided in Sec. 5(c) is specious at best and does not commend
itself for concurrence.
As aptly noted by the CA, the Sec.
5(c) “needs of the company” factor, if viewed by its lonesome self without
linking it to the Sec. 1 criteria, would be a meaningless, if not unreasonable,
standard. Worse still, it may well-nigh give MMPC a carte blanche and unchecked
license to determine what the needs of the company would be relative to the
lay-off, retrenchment, or retention of any employee. Such construal as espoused
by Alfredo cannot be allowed for Sec. 1 expressly mandates the use of salient
criteria to be considered in lay-off situation and other personnel movements.
In all, there is really no irreconcilable conflict between Secs. 1 and 5; they
can and ought to be harmonized and read in conjunction with each other.
The proper view, therefore, is that
the Sec. 1 criteria qualify the factors of “seniority and needs of the company”
in Sec. 5(c). Stated a bit differently, Sec. 5(c) should be understood in the
light of Sec. 1 which, to stress, provides seniority, efficiency and attitude,
job knowledge and potential, and attendance as among the factors that should guide
the company in choosing the employees to be laid-off or kept. All other things
being equal, a company would necessarily need to retain those who had rendered
dedicated and highly efficient service and whose knowledge, attendance, and
potential hew with company standards. Any other measure would be senseless in
the business viewpoint. Accordingly, the
merit rating used by MMPC based on Sec. 5 in conjunction with and as qualified
by the factors provided under Sec. 1 is fair and reasonable, and, to be sure,
well within the contemplation of the parties’ CBA. In fact, Alfredo, shorn of the contention
that the merit rating is against the CBA, has not shown any arbitrariness on
the part of MMPC in the evaluation, selection, and retrenchment of
employees.
We end this ponencia by taking stock that 60 of the first batch of 531 hourly
employees retrenched in February 1998 challenged the legality of their
retrenchment on the very same issue of arbitrariness in the implementation of the
rating evaluation system. The labor
arbiter, the NLRC, and effectively the CA were one in their ruling that the
retrenchment program and the evaluation method used by MMPC passed the test of
reasonableness and were arrived at in good faith; thus, the retrenchment was
held legal and valid. In G.R. No. 155406, the Court found no reversible error
in the CA judgment and dismissed the petition of the retrenched employees,
thereby upholding the validity of retrenchment undertaken by respondent
company.[20] The same result obtains in the instant
petition.
WHEREFORE, the
instant petition is hereby DENIED
for lack of merit. Accordingly, the
Decision dated
No pronouncement as to costs.
SO ORDERED.
PRESBITERO
J. VELASCO, JR.
Associate Justice
WE
CONCUR:
Associate Justice
Chairperson
Associate Justice Associate
Justice
ARTURO D.
BRION
Associate Justice
I attest that the
conclusions in the above Decision had been reached in consultation before the
case was assigned to the writer of the opinion of the Court’s Division.
Pursuant to Section 13,
Article VIII of the Constitution, and the Division Chairperson’s Attestation, I
certify that the conclusions in the above Decision had been reached in
consultation before the case was assigned to the writer of the opinion of the
Court’s Division.
REYNATO S. PUNO
Chief Justice
[1] Rollo, pp. 68-80. Penned by Associate Justice Portia Aliño-Hormacheulos and concurred in by Associate Justices Rebeccah De Guia-Salvador and Aurora Santiago-Lagman.
[2]
[3]
[4]
[5] Supra note 2, at 147-148.
[6] Supra note 1, at 79-80.
[7] Rollo, pp. 410-411.
[10]
G.R. No. 152039,
[11] Rollo, pp. 201-203. MMPC’s AFS for 1997 and 1998.
[15] Labasan v. Lacuesta¸ No. L-25931, October 30, 1978, 86 SCRA 16, 21; cited in Ayala Life Assurance, Inc. v. Ray Burton Development Corporation, G.R. No. 163075, January 23, 2006, 479 SCRA 462, 467-468.
[16] New Life Enterprises v. Court of Appeals, G.R. No. 94071, March 3l, 1992, 207 SCRA 669, 675.
[17] Reparations
Commission v. Northern Lines, Inc., No. L-24835,
[18] Art. 1374. The various stipulations of a contract shall be interpreted together, attributing to the doubtful ones that sense which may result from all of them taken jointly.
[19] Rivera v. Espiritu, G.R. No. 135547, January 23, 2002, 374 SCRA 351, 363-364; citing Reparations Commission, supra.
[20] Rollo, p. 281.