G.R. No. 166039 - Digitel Telecommunications Philippines, Inc. vs. Soriano

In the third quarter of 1998, Digitel Telecommunications Philippines, Inc. (Digitel) hired respondent Mariquit Soriano (Mariquit), aged 48, as Director for Market and Communications effective August 15, 1998.
Mariquit was a Bachelor of Science in Nutrition graduate from the University of the Philippines and a graduate school student at De La Salle University (unfinished thesis).
Mariquit's immediate superior was Senior Vice President Eric J. Severino (Severino), while Senior Executive Vice President Johnson Robert L. Go (Go) was the next higher superior.
Mariquit supervised three managers: Evelyn P. Inductivo (Promotion Section), Andrea S. Arnedo (Corporate and Planning Information Section), and Joselito Macachor (Ad and Promo Manager).
During the first performance review (Aug 1998 - Feb 1999), Mariquit received a 92% rating ("Above Average").

Mariquit had a rift with Macachor over an advertisement error; she sought his termination which was refused by Severino, who only transferred Macachor to another department.
Following this, Mariquit’s performance deteriorated, as reflected in the April 1999 - April 2000 review with a 60% rating ("Average"). Severino noted Mariquit needed to improve commitment and work atmosphere.
Mariquit gave unfavorable ratings to her two managers Evelyn and Andrea; both contested the ratings and accused her of harassment and violation of company policies in their memoranda addressed to Severino.
Mariquit demanded termination of Evelyn and Andrea, but management retained them.

Mariquit submitted a resignation letter dated June 28, 2000, effective June 30, 2000; Severino acknowledged receipt and forwarded it to HR.
On August 22, 2000, Mariquit executed a Deed of Quitclaim and Release, acknowledging receipt of P97,560.02 and declaring her resignation was voluntary, releasing Digitel from any claims.

About five months later, in January 2001, Mariquit met with Go and Executive VP Policarpio B. Pau, Jr. (Pau) for financial assistance; Pau perceived Mariquit’s request as an attempt to extort money to settle her case.
On May 28, 2001, Mariquit filed criminal complaints against Go and Severino for alleged sexual harassment (R.A. 7877) and acts of lasciviousness (Art. 336 RPC).
The Quezon City Prosecutor initially dismissed the complaints but later found probable cause against Go. Go appealed to the DOJ, which reversed the finding and ordered withdrawal of information due to lack of probable cause.

On December 20, 2001, Mariquit filed a complaint for illegal dismissal (later clarified as constructive dismissal) before the NLRC.
Mariquit alleged professional and sexual harassment by petitioners Severino and Go, compelling her resignation.
The Labor Arbiter dismissed the complaint, ruling that Mariquit voluntarily resigned and did not sufficiently prove harassment or coercion.
The NLRC affirmed the Labor Arbiter’s dismissal, emphasizing Mariquit’s threats of resignation relating to transfer demands and lack of evidence of forced resignation.

Mariquit filed a petition for certiorari with the Court of Appeals (CA) which reversed the NLRC, declaring her illegally dismissed and ordering payment of back wages, separation pay, damages, and attorney’s fees.
CA gave credence to a psychological evaluation report (Dr. Estrella T. Tiongson-Magno) indicating Mariquit suffered trauma consistent with sexual harassment.
CA discounted affidavits of petitioners’ witnesses as biased and gave weight to Mariquit’s accounts of harassment.

Petitioners filed a petition for review on certiorari before the Supreme Court, challenging the CA’s findings on factual and legal grounds.
They argued the CA misappreciated evidence, disregarded substantial evidence supporting voluntary resignation, improperly credited Mariquit’s psychological report, and erred in awarding damages.

Whether Mariquit was constructively dismissed by petitioner-employers due to professional and sexual harassment.
Whether the findings of the NLRC in favor of petitioners were supported by substantial evidence and free from grave abuse of discretion.
Whether the Court of Appeals erred in reversing the NLRC’s factual findings and in accepting Mariquit’s claim of sexual harassment and constructive dismissal.
Whether the psychological evaluation report submitted by Mariquit was properly given weight by the Court of Appeals.