Title
Dy Chua Bartolome vs. Toyota Quezon Avenue, Inc. et al.
Case
G.R. No. 254465
Decision Date
Apr 3, 2024
Bartolome alleged constructive dismissal from Toyota Quezon, claiming hostile work environment and unfair treatment. The Court ruled in favor of Bartolome, finding his resignation was involuntary and due to employer's actions.

Case Digest (G.R. No. 254465)
Expanded Legal Reasoning Model

Facts:

  • Employment Background of Petitioner
    • Jonathan Dy Chua Bartolome (petitioner) was hired in March 2009 by Toyota Quezon Avenue, Inc. (TQAI) as a marketing professional trainee in the Vehicles Sales Department.
    • In August 2010, he became a regular employee tasked with selling Toyota brand cars, products, and services.
  • Notices of Alleged Habitual Absences and Suspension
    • On December 28, 2015, petitioner received notices from TQAI Human Resources Department regarding habitual absences for October and November 2015.
    • Petitioner was also placed under a seven-day suspension for a third offense related to absences.
  • January 22, 2016 Meeting and Subsequent Remarks
    • Petitioner attended a meeting with management assisted by his sibling as counsel, after which he believed the issue was settled.
    • At a subsequent marketing professionals’ meeting, TQAI President Lincoln T. Lim made derogatory remarks against petitioner for bringing his lawyer-sibling, indicating disdain and hostility.
  • January 25, 2016 Incidental Car Sale Incident
    • Petitioner was tasked to process a car sale involving a vehicle with a leather cover seat not included in the package.
    • Petitioner handed over signed documents but was not involved in ordering the leather cover.
    • He asked TQAI Group Retail Manager Josefina De Jesus for an investigation, but De Jesus gave sarcastic remarks implying petitioner’s sole liability.
  • Handling of Incident and Subsequent Transfer and Account Withdrawals
    • De Jesus paid for the leather seat cover without petitioner’s consent, creating an impression of liability on him.
    • Petitioner’s accounts were withdrawn and transferred to another marketing professional without explanation.
    • Petitioner was transferred to another team on March 1, 2016.
    • General Sales Manager Esteban Dela Paz prevented petitioner from processing sales under certain accounts and denied authorization signatures for his transactions.
  • Hostile Treatment and Pressure to Resign
    • New team leader Susan SobreviAas asked petitioner if he planned to resign, indicating attempts to push him out.
    • Petitioner was coerced to sign altered performance scorecards and was asked to explain failures to meet sales quotas while accounts had been withdrawn.
    • Petitioner experienced discrimination in vehicle unit allocations and was subjected to unduly harsh treatment at work.
  • Petitioner's Resignation and Aftermath
    • Enduring hostile working conditions, petitioner tendered his resignation on March 31, 2016, effective April 30, 2016, and requested terminal leave starting April 4, 2016.
    • Petitioner faced harassment during clearance processing starting April 21, 2016, and received incomplete salary and unpaid commissions.
    • On August 4, 2016, he filed a Complaint for illegal/constructive dismissal and money claims before the NLRC, asserting he was constructively dismissed.
  • Proceedings and Decisions Prior to the Supreme Court
    • Labor Arbiter found respondents liable for constructive dismissal, ordering full backwages, separation pay, unpaid commissions, moral and exemplary damages, attorney’s fees, and documentary obligations.
    • NLRC affirmed the decision with modification but exempted certain respondents from personal liability.
    • The Court of Appeals reversed the lower tribunals’ rulings, ruling petitioner voluntarily resigned and was not constructively dismissed.
    • Petitioner sought review before the Supreme Court to overturn the Court of Appeals' decision.

Issues:

  • Whether petitioner was constructively dismissed by respondents, rendering his resignation involuntary.
  • Whether the acts and conduct of the respondents amounted to hostile work environment, clear discrimination, or undue degradation justifying constructive dismissal.
  • Whether petitioner’s resignation letter was voluntary and genuine or coerced and involuntary.
  • Whether respondents are solidarily liable for the monetary claims including backwages, separation pay, commissions, damages, and attorney’s fees.
  • Whether petitioner is entitled to moral and exemplary damages, and attorney’s fees.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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