Facts:

Admiral Realty Company, Inc., the petitioner in this case, employed Angelina M. Balani as a Cost Controller at Admiral Hotel from July 1976 until her resignation on June 30, 1991. Balani faced allegations of misconduct through a memorandum dated June 21, 1991, issued by the hotel's Managing Director, Ma. Victoria A. Concepcion. The memo accused her of entertaining personal visitors during office hours, excessive personal phone calls, and conducting money-lending activities with co-employees. Balani responded on June 22, 1991, denying the allegations. However, on June 25, she submitted a letter of resignation that was accepted with regret by the company on June 28, 1991. The hotel subsequently issued a clearance certifying that Balani had no outstanding obligations as of her resignation date.

Following her separation, Balani received her salary and benefits totaling P64,465.80 in the subsequent days, and on July 18, 1991, she executed a release and quitclaim in favor of Admir

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Facts:

Background of Employment

• In July 1976, Admiral Hotel hired Angelina M. Balani as Cost Controller.
• Balani served in that capacity for fifteen (15) years.

Disciplinary Proceedings and Memorandum

• On June 21, 1991, petitioner Admiral Realty, through Managing Director Ma. Victoria A. Concepcion, issued a memorandum to Balani.
• The memorandum accused Balani of several violations including entertaining personal visitors during office hours, frequent personal calls, and engaging in non-work-related lending of money.
• It cautioned her that disciplinary action might follow if she failed to provide an explanation within 48 hours.
• The tone of the memorandum implied that her extracurricular activities were affecting her regular work and required urgent attention.
• On June 22, 1991, Balani responded to the memorandum by denying the alleged charges.

Resignation and Final Employment Procedures

• On June 25, 1991, Balani tendered her letter of resignation, effective as of the close of office on June 30, 1991.
• On June 28, 1991, petitioner accepted the resignation with expressed regret.
• On June 29, 1991, a certificate of clearance was issued by the hotel’s personnel officer, indicating that Balani had been cleared of obligations upon her exit.
• Subsequent financial settlements were carried out:
• On July 16, 1991, Balani received a consolidated amount (P10,898.10) covering salary, overtime, vacation, sick leave, 13th month pay, and service charge participation.
• On July 17, 1991, she received separation benefits amounting to P53,567.70.
• On July 18, 1991, Balani executed a release and quitclaim favoring the petitioner.

Filing of the Complaint and Labor Arbiter Proceedings

• On August 13, 1991, Balani filed a complaint with the Labor Arbiter alleging forced resignation/harassment due to the disciplinary actions and office transfer issues.
• On November 29, 1991, Labor Arbiter Benigno C. Villarente, Jr. issued a decision declaring that while harassment incidents occurred, there was no evidence that Balani was forced to resign.
• The decision awarded Balani a tangible financial assistance equivalent to four months of her basic pay (or a specified monetary amount).

Appeals and Subsequent Decisions

• Both parties appealed the Labor Arbiter’s decision to the National Labor Relations Commission (NLRC).
• On May 25, 1993, the NLRC rendered a decision reversing the Labor Arbiter’s findings regarding the resignation.
• Petitioner then sought reconsideration on June 17, 1993, which was denied by the NLRC on June 22, 1993, for lack of merit.
• The petitioner subsequently elevated the case to the Supreme Court via a petition for certiorari.

Issue:

Whether the resignation of Angelina M. Balani was truly voluntary or if it amounted to constructive dismissal due to alleged harassment and unfavorable office transfer.

• The contention that a change in office location (from under the stairs to the kitchen) amounted to harassment inducing forced resignation.
• Whether the disciplinary memorandum constituted an act of harassment that eliminated any reasonable option but to resign.

Whether the decision of the National Labor Relations Commission (NLRC) was rendered with grave abuse of discretion amounting to lack or excess of jurisdiction.

• Assessing if NLRC’s ruling ordering payment of backwages and separation benefits was justified.
• Determining if the findings of forced resignation and harassment were supported by the evidence.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)