MANOLO A. PEÑAFLOR vs. OUTDOOR CLOTHING MANUFACTURING CORPORATION (G.R. No. 177114. January 21, 2010) FACTS: Peñaflor was hired on September 2, 1999 as probationary HRD Manager of respondent Outdoor Clothing Manufacturing Corporation. Peñaflor claimed that his relationship with Outdoor Clothing went well during the first few months of his employment. His woes began when the company’s Vice President for Operations, Edgar Lee, left the company after a big fight between Lee and Chief Corporate Officer Nathaniel Syfu. Because of his close association with Lee, Peñaflor claimed that he was among those who bore Syfu’s ire. After Peñaflor returned from his field work on March 13, 2000, his officemates informed him that while he was away, Syfu had appointed Nathaniel Buenaobra as the new HRD Manager. He tried to talk to Syfu to clarify the matter, but was unable to do so. Peñaflor claimed that under these circumstances, he had no option but to resign. He submitted a letter to Syfu declaring his irrevocable resignation from his employment with Outdoor Clothing effective at the close of office hours on March 15, 2000. Peñaflor then filed a complaint for illegal dismissal with the labor arbiter, claiming that he had been constructively dismissed. Outdoor Clothing denied Peñaflor’s allegation of constructive dismissal. It posited instead that Peñaflor had voluntarily resigned from his work. The labor arbiter agreed with Penaflor and issued a decision in his favor. favor. On appeal, the NLRC NLRC reversed reversed the arbiter’s arbiter’s decision and and the CA affirmed the NLRC’s NLRC’s decision. Hence, petitioner filed filed a petition for review before before the SC.
ISSUE: Can Peñaflor’s resignation be considered as constructive dismissal equivalent to an illegal dismissal?
RULING: Yes. Peñaflor started working for the company on September 2, 1999 so that by March 1, 2000, his probationary period would have ended and he would have become a regular employee. We find it highly unlikely that he would resign on March 1 and would simply leave given his undisputed record of having successfully worked within his probationary period. It does not appear sound and logical to us that an employee would tender his resignation on the very same day he was entitled by law to be considered a regular employee, especially when a downsizing was taking place and he could have availed of its benefits if he would be separated from the service as a regular employee. It was strange, too, that he would submit his resignation on March 1 and keep quiet about this until its effective date on March 15. In our view, it is more consistent with human experience that Peñaflor indeed learned of the appointment of Buenaobra only on March 13, 2000 and reacted to this by tendering his resignation letter after realizing that he would only face hostility and frustration in his working environment. Three very basic labor law principles support this conclusion and militate against the company’s case. The first is the settled rule that in employee termination disputes, the employer bears the burden of proving that the employee’s dismissal was for just and valid cause. That Peñaflor did indeed file a letter of resignation does does not help the company’s case as, other than the fact of resignation, the company must still prove that the employee voluntarily resigned. There can be no valid resignation where the act was made under compulsion or under circumstances approximating compulsion, such as when an employee’s act of handing in his resignation was a reaction to circumstances leaving him no alternative but to resign. In sum, the evidence does not support the existence of voluntariness in Peñaflor’s resignation.
Another basic principle is that expressed in Article 4 of the Labor Code—that all doubts in the interpretation and implementation of the Labor Code should be interpreted in favor of the workingman. Thus, we find that Peñaflor was constructively dismissed given the hostile and discriminatory working environment he found himself in, particularly evidenced by the escalating acts of unfairness against him that culminated in the appointment of another HRD manager without any prior notice to him. Where no less than the company’s chief corporate officer was against him, Peñaflor had no alternative but to resign from his employment. Last but not the least, we have repeatedly given significance in abandonment and constructive dismissal cases to the employee’s reaction to the termination of his employment. We find from the records that Peñaflor sought almost immediate official recourse to contest his separation from service through a complaint for illegal dismissal. This is not the act of one who voluntarily resigned; his immediate complaints characterize him as one who deeply felt that he had been wronged.