Case Digest (G.R. No. 243139)
Facts:
Domingo Naldo, Jr., Rogelio Benitez, Isidro Alfonso, Jr., Ronaldo Ledda, Bernardo Fabulare, Armando De Luna, and Nelson Villacentino v. Corporate Protection Services, Phils., Inc. and/or Buddy Robrigado and Benjamin Sesgundo, G.R. No. 243139, April 03, 2024, Supreme Court Second Division, Kho, Jr., J., writing for the Court.The petitioners (seven security guards) were employed by Corporate Protection Services, Phils., Inc. (CORPS) at sites in Tarlac and Cabanatuan and claimed underpayment and unlawful deductions (trust fund savings and cash bond) and nonpayment of various statutory benefits. Beginning January–March 2015 they availed themselves of the DOLE NCMB Single-Entry Approach (SEnA). During conciliation-mediation conferences on March 3 and March 10, 2015, CORPS’ representative, Benjamin Sesgundo, offered checks for the trust fund savings and cash bonds and asked petitioners to sign resignation letters and quitclaims in exchange for assurances that remaining monetary claims would be reconciled and paid. Petitioners later discovered the checks only covered the trust fund savings and cash bonds, were prevented from returning to work, and their other money claims remained unpaid.
On April 14 and May 4, 2015 petitioners filed consolidated complaints with the National Labor Relations Commission (NLRC) (later amended to add constructive illegal dismissal). The Labor Arbiter (LA) dismissed the complaints in an August 28, 2015 Decision, finding the resignations and quitclaims voluntary. Petitioners appealed to the NLRC. In its December 29, 2015 Resolution, the NLRC reversed the LA: it found petitioners had no intention to resign, declared the quitclaims invalid because the monetary claims were uncertain when signed, ordered petitioners to return to work and remanded the computation of money claims to the LA; its denial of motions for reconsideration was embodied in a February 24, 2016 Resolution.
Both parties filed petitions for certiorari with the Court of Appeals (CA) (consolidated as CA-G.R. SP No. 144925 and CA-G.R. SP No. 145329). The CA, in a Consolidated Decision dated February 15, 2018 (and a November 8, 2018 resolution denying reconsideration), concluded the NLRC did not commit grave abuse of discretion: petitioners were not guilty of forum shopping; the quitclaims and resignations were not binding because signed under assurances; nevertheless there was no illegal dismissal and remand to the LA for monetary computation was proper. Petitioners sought relief from the Supreme Court ...(Pro-only)
Issues:
- Are petitioners guilty of forum shopping for having availed themselves of SEnA then filing complaints with the NLRC?
- Are the quitclaims executed by petitioners before the SEnA officer legal and binding?
- Did the Court of Appeals err in ruling that petitioners were not constructively dismissed (i.e., were the resignation letters valid) and therefore not entitled to backwages, moral and exemp...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)