G.R. No. 177680 - Lagahit vs. Pacific Concord Container Lines

In February 2000, respondent Pacific Concord Container Lines, a domestic corporation engaged in cargo forwarding, hired Jennifer Lagahit as an Account Executive/Marketing Assistant.
In January 2002, she was promoted to Sales Manager with a monthly salary of P25,000.00 and was provided with additional benefits such as a brand new Toyota Altis and gasoline allowance.

On November 8, 2002, while performing her duties, Lagahit left the company premises early to make client calls.
At 1:14 p.m. that day, she received a text message from respondent Monette Cuenca stating, "TODAY U R OFFICIALY NT CONNECTED WITH US."
A similar text message was sent to her husband, Roy Lagahit, instructing the return of the company car and personal effects.
The petitioner later learned from clients and friends that the respondents had disseminated notices, flyers, and memos to all Pacific Concord clients announcing her termination, and a notice was published in the Sunstar Daily on December 15, 2002.

On November 13, 2002, Lagahit sent a letter to Pacific Concord requesting the settlement of due benefits and asserting that she was deprived of due process in connection with her termination.
Monette Cuenca responded on November 25, 2002, by sending a letter detailing a list of uncollected accounts, implying that her commission was withheld pending order, thereby suggesting a financial basis for her dismissal.

On November 26, 2002, the petitioner filed a complaint for constructive dismissal with the Regional Arbitration Branch of the NLRC in Cebu City.
The Labor Arbiter, rendering decision on June 9, 2003, held that the petitioner’s dismissal was illegal due to the lack of due process and the absence of notice regarding purported offenses, thus awarding separation pay and backwages.
The NLRC, upon appeal, affirmed the Labor Arbiter’s findings but modified the computation of separation pay and backwages. They found that the termination occurred without the observance of due process and rejected the contention that Lagahit had resigned voluntarily.

On May 10, 2006, the Court of Appeals (CA) issued a decision granting the respondents’ petition for certiorari, annulling the NLRC decision.
The CA held that there were sufficient justifications for terminating Lagahit’s employment based on allegations of disloyalty and willful breach of trust, citing acts such as applying for other jobs during office hours, enticement of her subordinate to resign, and engaging with competing cargo-forwarding companies.
The CA characterized these acts as grounds for a loss of trust and confidence, ultimately justifying her dismissal despite her position not being that of a managerial employee vested with broad authority.

The petitioner argued that she was terminated without her consent, explicitly disproving the contention that she had resigned, and maintained that her dismissal was illegal as she was deprived of due process.
The respondents contended that Lagahit’s behavior—seeking employment with and providing services to competing companies—breached the trust reposed in her as a sales manager and that her resignation was implicit in her actions and subsequent letter.

Whether the petitioner actually resigned from her employment or was unlawfully dismissed.

The CA relied on the respondents’ contention that Lagahit's subsequent letter amounted to a resignation, despite evidence indicating her termination.
Whether the absence of a clear, unconditional intent to relinquish the employer-employee relationship can negate the fact of unlawful dismissal.

Whether the evidence presented substantively proved that the petitioner committed acts constituting a willful breach of trust and disloyalty sufficient to justify her termination.

The validity of the respondents’ reliance on affidavits and speculative evidence to claim disloyalty.
Whether Lagahit’s actions—such as job applications and client referrals to competing companies—were enough to erode the employer’s trust, especially given her role’s classification among employees with trust and confidence.

The proper standard of evidence required to prove that the termination was for a just cause or authorized ground under the Labor Code.

The burden of proof on the employer to establish that the petitioner’s actions constituted a deliberate and willful breach of trust.