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	GR No. 171282 2013-11-27	SKM ART CRAFT CORPORATION v. EFREN BAUCA VILLARAMA, JR., J.
In Waterfront Cebu City Hotel v. Jimenez,[30] we also said: Under Art. 286 of the Labor Code, a bona fide suspension of business operations for not more than six (6) months does not terminate employment. After six (6) months, the employee may be recalled to work or be permanently laid off. In this case, more than six (6) months have elapsed from the time the Club ceased to operate. Hence, respondents' termination became permanent.
	GR Nos. 184903-04 2012-10-10	DIGITAL TELECOMMUNICATIONS PHILIPPINES v. DIGITEL EMPLOYEES UNION PEREZ, J.
In the recent case of Waterfront Cebu City Hotel v. Jimenez,[23] we referred to the closure of a department or division of a company as retrenchment. The dismissed employees were undoubtedly retrenched with the closure of Digiserv.