Title
Auza, Jr. vs. MOL Philippines, Inc.
Case
G.R. No. 175481
Decision Date
Nov 21, 2012
Employees resigned voluntarily, received benefits, and signed quitclaims; claims of coercion and illegal dismissal dismissed due to lack of evidence and procedural delays.
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Case Digest (G.R. No. 175481)

Facts:

Employment and Resignation:

  • Respondent MOL Philippines, Inc. (MOL), a common carrier, employed petitioners Dionisio F. Auza, Jr., Adessa F. Otarra, and Elvie Jeanjaquet in various positions from 1997.
  • In October 2002, Otarra, Auza, and Jeanjaquet submitted their resignation letters, effective November 2002. They received separation pay, leave credits, and other benefits, signing documents acknowledging receipt and executing release and quitclaims.

Legal Proceedings:

  • In February 2004, nearly 15 months after their resignation, petitioners filed complaints for illegal dismissal before the National Labor Relations Commission (NLRC), alleging that their resignations were coerced and based on misrepresentation that the Cebu branch would be downsized.
  • The Labor Arbiter dismissed the complaints for failure to file a timely Position Paper, ruling that petitioners failed to prosecute their case.
  • The NLRC reversed the Labor Arbiter’s decision, finding that the resignations were invalid and executed under duress. It ruled that petitioners were illegally dismissed and awarded reinstatement, backwages, damages, and attorney’s fees.
  • Respondents filed a Petition for Certiorari with the Court of Appeals (CA), which reversed the NLRC’s decision, holding that petitioners voluntarily resigned and were not illegally dismissed.

Issue:

  1. Whether the Court of Appeals acted without jurisdiction in reversing the NLRC’s decision.
  2. Whether petitioners were constructively dismissed.
  3. Whether petitioners voluntarily resigned from their jobs.
  4. Whether the releases and quitclaims executed by petitioners were valid and barred their claims.
  5. Whether the Court of Appeals erred in giving due course to the Petition for Certiorari despite procedural lapses.
  6. Whether petitioners are entitled to reinstatement, backwages, damages, and attorney’s fees.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court affirmed that petitioners voluntarily resigned and were not illegally dismissed. The quitclaims they executed were valid, and their claims for reinstatement, backwages, and damages were denied. The Court emphasized that technicalities should not hinder the fair resolution of labor disputes, but in this case, the evidence supported voluntary resignation.


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