G.R. No. 205912 - Gatan vs. Vinarao

Leticia P. Perez was hired by Diliman Preparatory School (the School) in 1972 as an elementary teacher.
She was a regular teacher handling Grade III students for several years.
In 1994, Perez was assigned to teach Grade V students with working hours from 7:30 a.m. to 12:30 noon.

In August 1994, several students reported Perez collected payments for Saranggola magazine subscriptions but did not remit them or deliver magazines.
The School created an investigation committee; Perez admitted failure to remit payments due to busy schedule but agreed to return monies.
By February 1995, only 5 of 20 students received refunds; the rest were paid in installments.
The committee found evidence indicating possible misappropriation, downgraded to negligence due to her long service, and recommended a 10-working-day suspension without pay.
Perez was suspended from April 10 to 25, 1995.

In January 1995, a cheating incident occurred during the Grade V Math quarterly exams proctored by Perez.
Another teacher reported the student copied answers with Perez’s consent.
An investigation confirmed Perez’s negligence and highly irregular conduct.
Perez admitted involvement in letters to the School president.
She was suspended from May 26 to June 11, 1995 with one week commutation.

Perez did not report back to work after suspension; instead, she sent a handwritten resignation letter on June 14, 1995 stating she needed to accompany her veteran father to the United States.
Perez received all due benefits under the Private Education Retirement Annuity.
After nearly three years, on June 15, 1998, Perez filed a complaint for separation benefits alleging constructive dismissal.
She claimed she was demoted to floating status requiring longer hours without additional pay and forced to perform non-teaching duties.
Perez admitted she never left the Philippines and gave the resignation reason to avoid antagonism.

Petitioners argued Perez’s cause of action prescribed under Article 291 of the Labor Code since three years had elapsed.
They denied constructive dismissal and demotion, explaining reassignment was due to school year timing and Perez’s salary and benefits remained the same.
The School denied granting separation pay to others, stating such payments were financial assistance, not policy.
The Labor Arbiter (LA) ruled Perez resigned voluntarily but granted separation pay due to a practice of paying such upon resignation; denied constructive dismissal claim.
The National Labor Relations Commission (NLRC) modified the LA decision, recognizing constructive dismissal due to floating status but dismissed the claims against Coseteng personally.
The Court of Appeals (CA) affirmed Perez’s constructive dismissal and entitlement to separation pay, rejecting prescription and reinstating attorney's fees.

Whether Perez’s cause of action for constructive dismissal and separation pay has prescribed.
Whether Perez was constructively dismissed from employment.
Whether Perez was demoted or placed on floating status.
Whether the School has an established practice or policy of granting separation pay to resigned employees.
Whether petitioners are entitled to moral damages, exemplary damages, and attorney's fees due to Perez’s alleged coercive litigations.