Grande v. Philippine Nautical Training College
REITERATIONFacts
The Antecedents: Flordaliza Llanes Grande was employed by Philippine Nautical Training College (PNTC) as an instructor in 1988, eventually rising to the position of Director for Research and Course Department and Assistant Vice-President for Training Department. In March 2011, PNTC's President allegedly instructed a Vice President to tell Grande to resign due to alleged anomalies in the Registration Department that reportedly involved her, with assurances of absolution if she complied. Grande then submitted a resignation letter effective March 2, 2011. The following day, she filed a police blotter for unjust vexation against the Vice President and a complaint for illegal dismissal against PNTC. Procedural History: The Labor Arbiter ruled that Grande's resignation was a result of forced resignation and declared it null and void, ordering reinstatement without backwages or separation pay. The National Labor Relations Commission (NLRC) affirmed this decision. Subsequently, the Court of Appeals (CA) initially affirmed the NLRC's ruling, granting backwages. However, upon reconsideration, the CA reversed its earlier decision, dismissing Grande's complaint. This led to the present petition before the Supreme Court. The Petition: Grande filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to annul the CA's Amended Decision. She argued that the CA erred in issuing conflicting decisions and in considering the petition for certiorari despite the absence of grave abuse of discretion by the lower labor tribunals. Grande contended that her resignation was not voluntary but was induced by undue influence and pressure, evidenced by her immediate filing of a police blotter and an illegal dismissal complaint, and that the respondent failed to prove the voluntariness of her resignation. The respondent, PNTC, maintained that Grande voluntarily resigned to evade potential charges and that her actions were premeditated.
Issue(s)
Whether the Court of Appeals erred in issuing conflicting decisions and in considering the Petition for Certiorari filed by the respondent despite the absence of grave abuse of discretion on the part of the Labor Arbiter and NLRC. Whether petitioner Flordaliza Llanes Grande voluntarily resigned or was illegally dismissed.
Ruling
The Supreme Court granted the petition, set aside the assailed Amended Decision and Resolution of the Court of Appeals, and affirmed the Decision and Resolution of the National Labor Relations Commission with modification. Petitioner Flordaliza L. Grande was granted payment of backwages and attorney's fees.
Ratio Decidendi
On the issue of conflicting decisions and the CA's consideration of the petition for certiorari: The Court noted that the CA's Amended Decision reversed its earlier ruling without new arguments presented in the motion for reconsideration. However, the primary focus of the Supreme Court's review was the substantive issue of illegal dismissal. The Court reiterated that factual findings of the NLRC, when coinciding with those of the LA and supported by substantial evidence, are accorded respect and finality. While generally conclusive, the CA's findings are subject to exceptions, such as when they contradict lower courts or administrative bodies, compelling a further calibration of evidence. On whether petitioner voluntarily resigned or was illegally dismissed: The Court held that for an employer to successfully interpose the defense of voluntary resignation in an illegal dismissal case, they must prove by clear, positive, and convincing evidence that the resignation was voluntary. The employer cannot rely on the weakness of the employee's evidence. In this case, respondent PNTC was silent regarding the alleged meeting on March 1, 2011, where petitioner claimed she was pressured to resign. Neither Pios nor Fabia denied the meeting through an affidavit. The Court found it contradictory that PNTC claimed to have become suspicious of the resignation's abruptness, prompting an investigation, when its own comment admitted that a confrontation occurred before the resignation and that petitioner was confronted with discrepancies. The Court also found it illogical that petitioner, an Assistant Vice-President, was immediately cleared by all departments if she was indeed under investigation for anomalies, especially since the Special Cash Audit Report indicated she was the one to be accounted for. The haste in issuing her clearance suggested that PNTC wanted her to leave. The Court emphasized that resignation must be a voluntary act with the intention of relinquishing the office, accompanied by the act of relinquishment. The totality of circumstances, including the terse resignation letter, her preparations for an upcoming inspection, the immediate filing of a police blotter, and the subsequent filing of an illegal dismissal complaint the very next day, strongly indicated that her resignation was not voluntary but was a result of undue influence and pressure. The Court reiterated that the filing of an illegal dismissal complaint is inconsistent with a voluntary resignation, as it belies any intention to relinquish employment. Therefore, the employer failed to discharge its burden of proving voluntary resignation, and the dismissal was deemed illegal. The Court concluded that petitioner was entitled to reinstatement with full backwages and attorney's fees, as provided under Article 279 of the Labor Code, to make her whole and uphold her constitutional right to security of tenure.
Main Doctrine
An employer asserting voluntary resignation as a defense against illegal dismissal must prove by clear, positive, and convincing evidence that the resignation was voluntary. The filing of a complaint for illegal dismissal immediately after tendering a resignation strongly belies the claim of voluntary resignation.