G.R. No. 145956 - Northwest Airlines vs. Laya

FCA Security and General Services, Inc. (FCA) employed the complainant as a security guard in July 1999.
The complainant was assigned to work at the RCBC branch in Pasay City, among other assignments.

An altercation occurred at the RCBC branch involving the complainant and George Chua, a driver of Dunkin Donuts, during which the complainant allegedly drew and pointed his service firearm at Mr. Chua.
A police complaint for grave threats was filed against the complainant, prompting internal investigation by FCA.

Following the investigation led by Investigating Officer Virgilio D. Tangente, the complainant was recommended a seven-day suspension.
Instead of accepting the suspension order, the complainant offered to voluntarily resign and was provided with a clearance form by FCA.
The complainant subsequently filed a complaint for illegal dismissal, contending that he had been placed on “floating status” (i.e., without assignment) for more than six months, thereby alleging constructive dismissal.

The Labor Arbiter ruled in February 2005 that the complainant had been illegally dismissed, awarding backwages and separation pay.
On December 17, 2007, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision and dismissed the complaint for lack of merit.
The Court of Appeals (CA), on certiorari, reinstated the Labor Arbiter’s ruling in July 2009, holding that the NLRC had abused its discretion by reversing the Arbiter.
The petitioners (FCA and/or Maj. Jose Laid, Jr.) appealed further, leading to the present issue before the Supreme Court.

The petitioners introduced a memorandum dated January 27, 2003, which relieved the complainant from his post at the RCBC branch and directed him to report to FCA Head Office for instructions and proper disposition.
Subsequent documents and investigation records, including the suspension order issued on February 5, 2003, supported the narrative of a voluntary resignation.
Affidavits from FCA officers and department heads corroborated the petitioners’ claim that the complainant had approached them to facilitate his resignation and obtain his clearance.
The complainant, in his reply, relied on the January 27, 2003 memorandum as evidence of his contention of being placed on floating status, alleging that he was never reassigned.

Whether the Court of Appeals erred in holding that the NLRC had gravely abused its discretion in reversing the Labor Arbiter’s decision.
Whether there was sufficient evidence to establish that the complainant voluntarily resigned, or alternatively, if his allegation of being placed on floating status—and thus constructively dismissed—was substantiated.