Travelaire & Tours Corp. v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: Private respondent Nenita I. Medelyn was employed as chief accountant by petitioner Travelaire & Tours Corp. She voluntarily resigned from her position on April 25, 1994. Subsequently, she filed a complaint seeking separation pay, service incentive leave pay, and 13th month pay. 2. Procedural History: The Labor Arbiter awarded private respondent her proportionate 13th month pay for 1994 but dismissed her other claims. Upon appeal by the private respondent, the National Labor Relations Commission (NLRC) modified the decision, ordering the petitioner to pay separation pay, citing established company practice. The petitioner's motion for reconsideration was denied, leading to the present petition. 3. The Petition: Petitioners filed a petition for certiorari under Rule 65 of the Rules of Court, assailing the NLRC's decision. They argue that the NLRC erred in awarding separation pay, as the general rule is that voluntary resignation does not entitle an employee to such benefits unless stipulated in a contract, CBA, or established company practice. Petitioners contend that the payments made to other resigned employees were acts of generosity and not indicative of a company policy. The petition seeks to overturn the NLRC's finding of an established company practice and its award of separation pay.
Issue(s)
Whether private respondent is entitled to separation pay despite her voluntary resignation. Whether the NLRC committed grave abuse of discretion in awarding separation pay based on an alleged company practice.
Ruling
The petition is dismissed, and the decision of the National Labor Relations Commission is affirmed. Petitioner is ordered to pay private respondent separation pay.
Ratio Decidendi
On whether private respondent is entitled to separation pay despite her voluntary resignation: The general rule is that a voluntarily resigning employee is not entitled to separation pay. However, exceptions exist if there is a stipulation in the employment contract or Collective Bargaining Agreement (CBA), or if the payment is sanctioned by established employer practice or policy. In this case, the private respondent claimed entitlement based on the fact that three former employees (Rogelio Abendan, Anastacio Cabate, and Raul C. Loya) who resigned between 1991 and 1996 were given separation pay. The petitioner admitted giving sums of money to Cabate and Loya, though termed as generosity and not equivalent to separation pay. The Court noted that regardless of the terminology ('ex gratia' or otherwise) and the amount, the fact remained that upon resignation, these employees received sums of money occasioned by their separation from the company. This established a company practice or policy. On whether the NLRC committed grave abuse of discretion in awarding separation pay based on an alleged company practice: The Court held that findings of fact of quasi-judicial bodies like the NLRC, when supported by substantial evidence, are accorded respect and even finality. Substantial evidence is defined as such relevant evidence that a reasonable mind might accept as adequate to justify a conclusion. The NLRC's finding of a company policy or practice of paying separation pay to resigning employees was supported by substantial evidence, as demonstrated by the payments made to three prior resigning employees. The petitioner failed to present countervailing evidence to disprove this practice. In certiorari proceedings under Rule 65, the Court's inquiry is limited to determining if the NLRC acted without or in excess of jurisdiction or with grave abuse of discretion. Since there was substantial evidence on record to support the NLRC's finding of a company policy/practice, no grave abuse of discretion was committed. Furthermore, the Court reiterated the principle that in controversies between a laborer and his master, doubts should be resolved in favor of the employee, aligning with the State's policy of extending maximum aid and protection to labor.
Main Doctrine
An employee who voluntarily resigns is not entitled to separation pay unless stipulated in the employment contract or CBA, or sanctioned by established employer practice or policy. The NLRC's finding of an established company practice of paying separation pay to resigning employees, supported by substantial evidence of prior payments to other resigning employees, is given respect and finality in certiorari proceedings, absent grave abuse of discretion.