Title
Cornworld Breeding Systems Corp. vs. Court of Appeals
Case
G.R. No. 204075
Decision Date
Aug 17, 2022
Lucena, a VP, faced public humiliation and demotion by Cornworld’s new management, leading to her constructive dismissal. SC ruled in her favor, awarding backwages and separation pay.

Case Digest (G.R. No. 146754)

Facts:

  • Background and Employment History
    • Lucena was hired by Cornworld Breeding Systems Corporation in August 1982 as a field labor employee.
    • Over time, she advanced within the company and was eventually appointed Vice President for Research and Development.
  • Change in Management and the January 2009 Incident
    • Following the stroke of then-Cornworld President Benito M. Domingo on January 16, 2009, Laureano C. Domingo assumed management.
    • On January 24, 2009, during a special meeting, Laureano berated Lucena for not attending meetings regularly and for failing to respond to communications.
    • The verbal exchange escalated with Laureano using demeaning language and instructing Lucena to leave the meeting while making disparaging remarks (e.g., “I don’t want crying ladies here, you get out…”).
  • Impact on Lucena’s Health and Subsequent Actions
    • Lucena claimed that the episode adversely affected her health, leading to hospitalization at the Cabanatuan Family Hospital for hypertension.
    • She applied for sick leave on January 26, 2009, citing her health condition.
    • Despite being on leave, on February 17, 2009, Lucena requested payment for her salary and incentive benefits, asserting that her employment had been left in limbo by the appointment of Alan Canama as Overseer of the Research and Development Department.
  • Allegations of Constructive Dismissal and Job Abandonment Claims
    • Lucena alleged that the appointment of Canama and the hostile treatment significantly altered her employment conditions, effectively placing her on “floating status” and amounting to constructive dismissal.
    • She further contended that threats against her person and life by the management compelled her to refrain from reporting to work, ultimately resulting in her filing a complaint for constructive dismissal on June 23, 2009.
    • Petitioners, i.e., Cornworld and/or Laureano, countered by arguing that Lucena voluntarily abandoned her position by failing to report for duty and that no actual or constructive dismissal took place.
  • Procedural History
    • The Labor Arbiter issued a decision on August 24, 2009, dismissing Lucena’s complaint for illegal dismissal for lack of merit.
    • On appeal, the National Labor Relations Commission (NLRC) in its March 24, 2010 Decision affirmed that neither constructive dismissal nor job abandonment occurred, noting that Lucena’s actions (such as filing for leave and promptly instituting her case) indicated her intent to continue employment.
    • The Court of Appeals (CA), however, in its February 8, 2012 Decision, reversed earlier findings by holding that Lucena was constructively dismissed and entitled her to backwages, separation pay, and attorney’s fees.
    • Petitioners filed a Petition for Certiorari under Rule 65 of the Rules of Court on November 22, 2012, arguing abuse of discretion, wrong remedy usage, and that Lucena abandoned her job.
    • The petition was later subjected to a motion for reconsideration, which was both denied by the CA and later reviewed by the Supreme Court.

Issues:

  • Whether Lucena’s employment was validly terminated by constructive dismissal or if she abandoned her job by failing to report for work.
    • Does the sexualized and demeaning treatment, coupled with the appointment of a replacement, render her employment conditions intolerable such that constructive dismissal occurred?
    • Is the filing of sick leave and prompt filing of the dismissal complaint indicative of her intent to continue employment?
  • Whether petitioners (Cornworld) correctly availed themselves of the remedy under Rule 65 for certiorari or should have instead filed a Petition for Review on Certiorari under Rule 45.
    • Was the petition filed within the reglementary period as required by the applicable rules of procedure?
    • Did the petition meet the procedural requirements, such as proof of service, necessary under the Rules of Court?
  • Whether the procedural and substantive due process requirements for a valid dismissal were complied with by Cornworld in termination or alleged abandonment.
    • Were the mandatory notices and the opportunity to be heard provided to Lucena?
    • Was the burden of proof met by Cornworld in establishing the employee’s abandonment of work?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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