G.R. No. 177279 - Commissioner of Internal Revenue vs. Gonzalez

On 13 April 2017, petitioner Ascent Skills Human Resources Services, Inc. (Ascent) deployed respondent Alma Tacda Manuel to the Kingdom of Saudi Arabia (KSA) for a two-year contract with a monthly salary of US$400.
Shortly after deployment, respondent complained about her working conditions and refused to work for her designated employer.

Respondent’s initial assignment was to work in Riyadh as indicated by her employment contract with Silver Contract, Ascent’s foreign principal; however, she was unexpectedly redirected to Abha, KSA.
Although a former employee of Silver Contract facilitated her transfer to United Project Company (UPC), respondent’s insistence on being treated per her original contract terms (working in Riyadh) set the stage for dispute.

On the third day at her employer’s house, respondent was subjected to sexual harassment by her employer, Raman, who pressured her to provide a massage and proceeded to molest her by inappropriate contact.
Respondent reported that despite her protests, the harassment continued intermittently, exacerbating her distress.
Subsequently, she experienced further maltreatment at UPC where she, along with seven other workers, was confined in an overcrowded, poorly ventilated space with insufficient food and water, contributing to a degrading and inhumane work environment.

Barely a month after repatriation, respondent filed a complaint alleging constructive dismissal, non-payment of the unexpired contract, moral and exemplary damages, and claims for sexual harassment, discrimination, maltreatment, and trafficking.
The Labor Arbiter (LA) rendered a decision on 19 December 2017 finding for respondent, characterizing her dismissal as constructive and awarding wages, moral damages (Php10,000), exemplary damages (Php10,000), and attorney’s fees.
On appeal, the National Labor Relations Commission (NLRC) reversed the LA ruling on the ground that respondent voluntarily resigned when she signed a letter indicating her intention to return to the Philippines.
The Court of Appeals (CA) later reversed the NLRC decision, reinstating the LA’s finding of constructive dismissal and modifying the award to include legal interest.
Petitioners then filed a petition for review before the Supreme Court under Rule 45 of the Rules of Court.

Petitioners contended that respondent voluntarily resigned by executing her letter of repatriation and that she had no claim to constructive dismissal.
Conversely, respondent maintained that she was forced to leave her employment due to the abusive and exploitative conditions imposed by her employer and the recruitment agency, thus constituting constructive dismissal.

Whether the Court of Appeals committed a reversible error in determining that the NLRC gravely abused its discretion by holding that respondent voluntarily resigned rather than being constructively dismissed.
Whether the totality of the circumstances—including the change in employment destination, sexual harassment, confinement at UPC, and the employer’s neglect—supports the finding of constructive dismissal.
Whether the execution of the repatriation letter can be deemed sufficient evidence of voluntary resignation in light of the coercive and unjust conditions experienced by respondent.