Facts:

The case involves the petitioners BMG Records (Phils.), Inc. and its Branch Manager Jose Yap, Jr., against private respondent Aida C. Aparecio and the National Labor Relations Commission (NLRC). Aparecio, hired as a promo girl by BMG's Cebu branch on September 2, 1990, filed a complaint on May 25, 1998, alleging illegal dismissal and non-payment of various benefits including overtime pay, holiday pay, separation pay, and others. Aparecio claimed she was compelled to resign on April 30, 1998, under the promise of payment for her benefits. In contrast, the petitioners argued that Aparecio and two other employees had voluntarily submitted their resignations, which were accepted. Aparecio was found to have had some accountability for shortages during inventory, leading to deductions from her final payments.

The Labor Arbiter dismissed Aparecio's complaint on October 27, 1998, concluding that she voluntarily resigned. However, upon appeal, the NLRC ruled on August 23, 2000,

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Facts:

Employment Relationship and Background

• BMG Records (Phils.), Inc., a company engaged in selling audio records nationwide, employed Aida C. Aparecio as a promo girl in its Cebu branch beginning September 2, 1990.
• Aparecio received a daily salary of P181.00 and was part of a workforce performing duties from Monday to Sunday.

Allegations and Complaint by Aparecio

• On May 25, 1998, Aparecio filed a complaint alleging illegal dismissal and non-payment of various employment benefits, including overtime pay, holiday pay, premium pay for rest days, 13th month pay, service incentive leave, and separation pay.
• In her Position Paper, she contended that:
• She was terminated on April 30, 1998, under conditions that effectively amounted to illegal dismissal, even though a resignation letter was executed.
• Prior to the alleged termination, she was induced to resign in exchange for a promise of full payment of benefits, essentially converting her termination into a resignation obtained under duress or inducement.
• The resignation letter was executed under the belief that petitioners would pay a one‑month pay for every year of service along with other benefits, but later a computation of accountabilities (amounting to P8,000.00) allegedly reduced the promised benefits.
• She maintained that her resignation was not made freely but was the product of economic and factual pressure, and even fraud, as she was misled into relinquishing her rights.

Petitioners’ Version of Events

• Petitioners (BMG Records and Jose Yap, Jr.) asserted that Aparecio’s performance had deteriorated over the years due to complacency and comparisons with industry peers in terms of wage levels.
• In April 1998, Aparecio, along with two other promo girls (Jovelina V. Soco and Veronica P. Mutya), voluntarily intimated their intention to resign and requested financial assistance.
• Under company policy, resigning employees were not entitled to financial assistance; however, BMG agreed to grant such assistance after the employees secured their individual clearances.
• Upon processing clearances, it was discovered that all three employees had incurred shortages (after inventory) which were deducted from their dues.
• While Soco and Mutya accepted the deductions by executing their releases and quitclaims, Aparecio objected to the deduction from her financial assistance and refused to sign the corresponding documents.

Procedural History and Conflicting Findings

• The Labor Arbiter initially ruled on October 27, 1998, dismissing Aparecio’s complaint on the ground that her resignation was voluntary as it was not evidenced that the resignation was compelled or made under duress.
• Subsequently, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision in its August 23, 2000 Decision by finding Aparecio was illegally dismissed; it ordered the payment of backwages and computed separation pay at one‑month pay for each year of service.
• The Court of Appeals (CA) in its November 20, 2001 Decision, affirmed the NLRC ruling, emphasizing that resignation is inconsistent with a complaint for illegal dismissal, and highlighting the imbalance of bargaining power between employer and employee.
• Petitioners later filed a motion for reconsideration, introducing additional sworn statements (from Soco and Marietta Cinco) that reiterated Aparecio’s voluntary resignation, which was subsequently denied.
• The petition for review under Rule 45 was thereafter filed, leading to the present review by the Supreme Court.

Evidentiary and Contextual Considerations

• The case presented conflicting evidence regarding the nature of the resignation, notably whether it was a voluntary act or stemmed from economic duress and inducement.
• While Aparecio claimed that her consent was vitiated by fraud, undue influence, and economic pressure, petitioners maintained that the resignation was clearly voluntary, as evidenced by the consistent actions leading to the processing of her clearance and acceptance of benefits.
• The evidentiary record showed discrepancies: the NLRC’s conclusion was partly based on an insufficient and speculative basis regarding the economic pressure alleged, whereas the petitioners’ evidence (including testimony and documentary evidence) suggested a voluntary resignation.

Issue:

Voluntariness of Resignation

• Whether Aida Aparecio tendered her resignation voluntarily or was induced by economic pressure, undue influence, or fraud to relinquish her employment rights.

Legal Implications of Conditional Resignation

• Whether a resignation tendered on the condition of receiving employment benefits can be equated with illegal dismissal if the conditions are later disputed or unfulfilled.

Evidentiary Sufficiency and Weight

• Whether the evidence on record, including the testimonies of other promo girls and the employment clearance procedures, sufficiently establishes the voluntary character of the resignation.

Appropriate Application of Legal Principles

• Whether the NLRC’s and the Court of Appeals’ findings correctly applied the principles regarding vitiation of consent and the finality of accepted resignations.

Discretion of the Employer in Accepting Resignation

• Whether the unilateral acceptance of the resignation by petitioners precludes any subsequent claim of illegal dismissal by the employee.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)