Facts:

• Magis Young Achievers' Learning Center and Mrs. Violeta T. Cariao are the petitioners.
• Adelaida P. Manalo was hired as a teacher and acting principal on April 18, 2002, with a monthly salary of P15,000.
• Manalo submitted her resignation on March 29, 2003, effective April 1, 2003, citing personal and family reasons.
• On March 31, 2003, the petitioners terminated her employment, citing a board resolution to abolish the principal position for cost-cutting.
• Manalo filed a complaint for illegal dismissal and non-payment of her 13th month pay on April 4, 2003, seeking reinstatement, back wages, and damages.
• The Labor Arbiter dismissed her illegal dismissal complaint but ordered payment of her 13th month pay.
• The NLRC reversed the Labor Arbiter's decision, ordering reinstatement and back wages.
• The Court of Appeals affirmed the NLRC's decision, prompting the petitioners to appeal to the Supreme Court.

Issue:

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Ruling:

• The Supreme Court ruled that Manalo's resignation was not effective due to the employer's lack of acceptance and the circumstances of her resignation.
• The Court determined that Manalo was not a permanent employee, as she had not completed the required three-year probationary period...(Unlock)

Ratio:

• The Supreme Court emphasized that resignation must be a voluntary act; in this case, Manalo's resignation was not entirely voluntary, as she filed a complaint for illegal dismissal shortly after.
• The Court noted that probationary employees have security of tenure during their probation,...continue reading