Petitioner
Daisy B. Tiu
Respondent
Platinum Plans Phil.
Citation
G.R. No. 163512
Court
Supreme Court
Division
Second Division
Ponente
Quisumbing, J.
Decided
February 28, 2007

Summary

This case involves the validity of a non-involvement clause in an employment contract. Daisy Tiu, former Senior Assistant Vice-President of Platinum Plans Philippines, Inc., violated a contractual provision prohibiting her from working in the same pre-need industry for two years after leaving the company. When she joined a competitor, Platinum Plans sued for P100,000 liquidated damages. The Supreme Court upheld the clause's validity, distinguishing it from earlier cases where restraints were unreasonable. The Court found the two-year limitation reasonable given Tiu's access to confidential marketing strategies and the competitive nature of the pre-need industry. The decision reinforces that non-involvement clauses are valid when they have reasonable limitations on time, trade, and place, and serve legitimate business interests in protecting confidential information.

Statutes applied

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By the Intellegal Editorial Board · February 28, 2007

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