G.R. No. 184397 - Paredes vs. Feed the Children Philippines, Incorporated

Petitioner Rosalinda G. Paredes served as the National Director of Feed the Children Philippines, Inc. (FTCP), a non-stock, non-profit, and non-government organization incorporated in 1989 with a mission to provide essential aid to indigent children worldwide.
Respondents include FTCP itself and three of its key personnel: Dr. Virginia Lao, Hercules Paradiang, and Benjamin Escobia, who were members of the Board of Trustees and the Executive Committee.
Petitioner’s roles involved project management, fund accessing, financial management, signing off on checks, approval of requisitions/disbursements, and implementation of Board resolutions as provided in the FTCP by-laws.

Hired in 1999 as Country Director, petitioner’s term was renewed several times. Her most recent contract spanned from October 1, 2004, to September 30, 2007, with a salary that increased from an initial US$1,000 to P70,000 plus other benefits and allowances.
As National Director, she also signed financial instruments for FTCP and was responsible for executing the Board’s decisions.

On August 12, 2005, a petition signed by 42 FTCP employees was submitted to the Board, listing allegations against petitioner including:

Granting inappropriate exemptions from policies she herself had approved.
Withholding funds despite Board approval.
Procuring health insurance for herself without contributing her share of the premium.
Receiving extra fees contrary to contractual terms.

On August 13, 2005, a meeting was convened by FTCP staff with Board members to address these complaints, which highlighted growing discord.
Petitioner became aware of a staff petition questioning her leadership after a meeting with Board Chairman Atty. Edgar Chatto.
On August 24, 2005, petitioner filed an administrative complaint against a Program Manager, Primitivo Fostanes, regarding alleged irregularities in management.

During an August 28, 2005 Board meeting, petitioner was initially excluded and only admitted after a delay of three hours.
The meeting discussed the friction between petitioner and the staff, and steps were taken:

Issuance of a back-to-work memorandum by acting Board Chair Lao.
Formation of a Supervisory Team (comprising Lao and Escobia) to draft a work plan.
Decision to have an independent professional management and financial audit conducted.

Petitioner, through letters and her lawyers, questioned the scope and propriety of the audit, demanding clarification and adherence to FTCP’s manual of operations.
On October 24, 2005, while attending an orientation, petitioner learned about the auditors’ arrival and was instructed by Lao to meet them; however, she insisted on receiving full requested information before compliance.
Petitioner later communicated via electronic mail to Feed the Children International’s founder, alleging that Board members had initiated a secret audit, and intimated legal action should she be illegally dismissed.

As tensions escalated, the Board resolved to suspend petitioner due to her refusal to submit to the audit, but before execution, petitioner tendered her resignation effective December 31, 2005.
The Board accepted her resignation on October 29, 2005, moving its effectivity to November 30, 2005, and agreed to pay her November salary to facilitate her transition.
Shortly after, petitioner filed a complaint for illegal dismissal, alleging forced resignation amounting to constructive dismissal, and impleaded Lao, Paradiang, and Escobia in their personal capacities.
The Labor Arbiter (LA) initially ruled in favor of FTCP and the Board, dismissing petitioner’s claim and ordering her to pay various sums for alleged accountabilities and damages.
The NLRC reversed the LA’s decision in a March 28, 2007 decision, ruling in petitioner’s favor by awarding her salaries, allowances, and damages, while absolving the individual respondents.
The Court of Appeals (CA) subsequently nullified the NLRC decision and reinstated the LA’s findings by declaring that petitioner had voluntarily resigned, and by ordering her to pay certain monetary claims for loans and withdrawals from the FTCP Provident Fund.
Petitioner elevated the matter to the Supreme Court via a petition for review on certiorari, contesting the CA's appreciation of facts and its application of established jurisprudence regarding constructive dismissal and the evaluation of money claims.

Whether the CA erred in delving into the factual findings of the NLRC, a decision generally accorded finality, and whether its application of the ruling in St. Martin Funeral Homes justified such review beyond the ordinary scope of certiorari.

Whether petitioner’s resignation should be deemed a case of constructive dismissal, given the allegations of exclusion from meetings, usurpation of her functions, and a hostile working environment.
Whether the evidence on record sufficiently proved that she was forced to resign due to discriminatory or oppressive conduct by the respondents.

Whether the CA properly applied the doctrine on “money claims of workers” under Article 217 of the Labor Code in awarding damages, particularly concerning claims for unpaid loans and reimbursement of withdrawn funds which may not have a direct connection to the employer-employee relationship.

Whether the CA’s decision undermined the constitutional and legal protections afforded to workers by interpreting management actions (such as the advancement of the resignation effectivity date) as harassment rather than as an exercise of management prerogative.