Title
Blue Eagle Management, Inc. vs. Naval
Case
G.R. No. 192488
Decision Date
Apr 19, 2016
BEMI faced financial losses, offered voluntary resignation to Naval with benefits; she resigned but later claimed coercion. Court ruled her resignation voluntary, no illegal dismissal.
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Case Digest (G.R. No. 192488)

Facts:

Petitioners' Account

  • Background of Petitioner BEMI: Blue Eagle Management, Inc. (BEMI) is a domestic corporation established in 2004 to manage and operate a sports complex. It commenced operations on January 2, 2005, under a Memorandum of Agreement (MOA) with Ateneo de Manila University (ADMU) to manage the Moro Lorenzo Sports Center (MLSC).
  • Respondent's Employment: Jocelyn L. Naval was hired by BEMI on January 15, 2005, as a maintenance staff member.
  • Financial Losses and Retrenchment Plan: In 2005, BEMI suffered significant financial losses (P5,067,409.44). To mitigate losses, BEMI decided to downsize its workforce in January 2006. Five employees, including Naval, were identified for retrenchment due to their short tenures.
  • Resignation Offer: Instead of retrenchment, BEMI offered the option to resign voluntarily, providing financial benefits such as full February 2006 salary, pro-rated 13th month pay, and financial assistance equivalent to one month’s salary per year of service.
  • Naval's Resignation: On February 20, 2006, Naval was informed of the downsizing plan and chose to resign voluntarily. She submitted a handwritten resignation letter, which was approved the same day. Naval was instructed to return on February 28, 2006, to complete exit procedures and receive her benefits.
  • Failure to Complete Exit Procedures: Naval did not appear on February 28, 2006, prompting BEMI to send her a letter on March 1, 2006, reminding her to complete the exit procedures. Naval appeared on March 3, 2006, and requested re-employment, which was denied. She then filed a complaint for illegal dismissal.

Respondent's Account

  • Incident Leading to Suspension: In December 2005, Naval was involved in an incident where a customer, Dr. Florendo, complained about her handling of a situation involving another customer. Naval was suspended for one day but was later allowed to return to work.
  • Alleged Coercion to Resign: On February 20, 2006, Naval was called to a meeting with BEMI’s HR Manager, Carmelita Dela Rama, and Ferdinand Tiongson. She was informed of the company’s need to reduce manpower and was pressured to resign. Naval claimed she was threatened with her husband’s job security if she did not comply. She was forced to submit a handwritten resignation letter dictated by Dela Rama.
  • Filing of Complaint: Naval did not complete the exit procedures and filed a complaint for illegal dismissal on March 3, 2006.

Issue:

  1. Whether Jocelyn L. Naval was illegally dismissed or voluntarily resigned.
  2. Whether the resignation was obtained through coercion or intimidation.
  3. Whether BEMI complied with legal requirements for retrenchment or voluntary resignation.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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