- 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.