Exception to the Toyota Doctrine


THE TOYOTA DOCTRINE (EXPANDED STRICT JUSTICE RULE)
Toyota Workers [TMPCWA] v. NLRC; G.R. Nos. 158786 and 158789, Oct. 19, 2007
<<<CLICK HERE FOR DOCTRINES ON GRANT OF SEPARATION PAY.>>>

The Toyota doctrine has expanded the coverage of excepted cases. Thus, the commission of any of the grounds in Article 282 of the Labor Code, except analogous causes, would not merit payment of financial assistance.

EXCEPTION TO TOYOTA DOCTRINE: WHEN TERMINATION IS BASED ON ANALOGOUS CAUSES.

Toyota, however, makes a distinction when the grounds cited are the analogous causes for termination under Article 282(e), like inefficiency, incompetence, ineptitude, poor performance and others. It declared that in these cases, the NLRC or the courts may opt to grant separation pay anchored on social justice in consideration of the length of service of the employee, the amount involved, whether the act is the first offense, the performance of the employee and the like, using the guideposts enunciated in PLDT on the propriety of the award of separation pay.

Yrasuegui v. PAL; G.R. No. 168081, October 17, 2008
(The Social Justice and Length of Service Rule)
This case is where the dismissal of petitioner (an international flight attendant) due to his obesity was held valid as an analogous cause under Article 282(e) of the Labor Code. The Supreme Court, however, as an act of social justice and for reason of equity, awarded him separation pay equivalent to one-half (1/2) month’s pay for every year of service, including his regular allowances. The Court observed that his dismissal occasioned by his failure to meet the weight standards of his employer was not for serious misconduct and does not reflect on his moral character.

International School Manila v. International School Alliance of Educators (ISAE), where the teacher was validly dismissed on the ground of gross inefficiency, an analogous cause, hence, falling under the exception in Toyota.

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