Case Digest (G.R. No. 206316)
Facts:
Panasonic Manufacturing Philippines Corporation (formerly Matsushita Electric Philippines Corp.) v. John Peckson, G.R. No. 206316, March 20, 2019, Supreme Court Third Division, Reyes, A., Jr., J., writing for the Court.Petitioner Panasonic Manufacturing Philippines Corporation (Panasonic) employed John V. Peckson as Sales Supervisor in its Battery Department. On September 16, 2003 Peckson submitted a letter of resignation effective October 30, 2003, and on September 25, 2003 he submitted a second resignation changing the effectivity to October 15, 2003. Peckson completed the exit interview and clearance procedures and signed a quitclaim and release; he also received his final pay.
On April 11, 2005 Peckson filed with the National Labor Relations Commission (NLRC) a complaint for constructive dismissal against Panasonic and Jose De Jesus (De Jesus), in his personal capacity as Peckson’s manager, alleging that De Jesus accused him of forging an “Authority to Travel” form dated August 20, 2003; Peckson procured a PNP Crime Laboratory report which he says established that De Jesus himself wrote the signature on the travel form. Peckson also alleged that De Jesus stripped him of supervisory functions, placed him on “floating status,” and threatened termination, which prompted his resignation.
Labor Arbiter Danna M. Castillon dismissed the complaint on November 28, 2006 for lack of merit, finding Peckson’s resignation voluntary (he submitted two resignation letters, completed exit procedures, and delayed filing his complaint). Peckson appealed to the NLRC; his appeal was initially dismissed as late but then given due course, and the NLRC, in a Decision dated September 30, 2010, affirmed the Labor Arbiter’s dismissal in toto.
The Court of Appeals (CA), however, reversed in a Decision promulgated December 7, 2012 (CA-G.R. SP No. 118641), finding that Panasonic failed to prove the voluntariness of the resignation and that Peckson was constructively dismissed; the CA awarded full backwages (from October 15, 2003 to April 11, 2005), separation pay, moral and exemplary damages, and attorney’s fees, holding Panasonic and De Jesus solidarily liable. Panasonic’s motion for reconsideration at the CA was denie...(Pro-only)
Issues:
- Was Peckson’s resignation voluntary?
- If the resignation was voluntary, are Panasonic and De Jesus liable for constructive dismissal and the damages awarded by the Court of...(Pro-only)
Ruling:
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Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)