G.R. No. 240484 - Pascual vs. Sitel Philippines Corp.

Petitioner's employment with Sitel commenced on October 27, 2006, when he was hired as an agent.
In 2014, petitioner was promoted to serve as a coach/supervisor for the Comcast Customer Service Group account, with a monthly salary of P25,000.00.

On October 9, 2014, petitioner was served a notice to explain regarding his failure to act on the case of Diosdado Jayson Remion, an agent in the Comcast CSG account who had been inactive since May 2014.
A second notice to explain was subsequently served, charging the petitioner with various causes including gross and habitual neglect of duties, with the charges eventually being revised to serious misconduct or willful disobedience of employer’s orders.

In his reply, petitioner requested that the charges be “particularized” so that he could raise appropriate defenses.
Despite his request, the respondents specified the acts allegedly committed by Remion and reiterated petitioner’s inaction, leading to the rescheduling of an administrative hearing on November 10, 2014.
Petitioner failed to attend the administrative hearing, citing the inadequacy and vagueness of the charges.

On November 21, 2014, a Notice to Decision was served, suspending petitioner for five days from November 26 to 30, 2014, with P6,896.58 withheld from his salary.
On December 2, 2014, petitioner received another notice to explain regarding his absences on several dates in November, prompting him to express the physical, emotional, and psychological impact of the situation.
Seeking redress, petitioner emailed the company requesting clarification, the release of unpaid salary, and a certificate of employment; however, his communications did not receive appropriate acknowledgment.

On December 11, 2014, petitioner personally delivered a resignation letter to a company representative (Reyes) and requested acknowledgment, which was refused.
Subsequent actions included petitioner sending additional copies of his resignation via email and registered mail.
Despite repeated manifestations of his intent to resign, further amounts (P7,842.11) were withheld from his salary.
Based on these events, petitioner asserted that he was constructively dismissed, arguing that oppressive and demeaning conduct by respondents forced him into resignation and that such actions amounted to illegal dismissal.

Respondents maintained that upon his appointment as coach/supervisor, petitioner was instructed to coordinate with the relevant teams regarding Remion’s case—a task which he failed to execute.
They contended that petitioner was given ample opportunity to address the charges through proper administrative channels, including notice to explain and a scheduled hearing, which he neglected to attend.
Respondents argued that the disciplinary actions, including the suspension and salary withholding, were justified responses to his negligence and failure to report on Remion's case.

The Labor Arbiter (LA) rendered a decision on September 8, 2015, dismissing petitioner’s complaint for illegal dismissal and declaring the suspension as legal, also noting that voluntary resignation precluded claims for reinstatement or recovery of forsaken benefits.
The National Labor Relations Commission (NLRC) affirmed petitioner’s appeal on March 4, 2016, ruling that the LA erred in interpreting the letter of resignation and associated circumstances; however, it later modified aspects of the decision, including by exonerating certain respondents on liability issues.
On January 15, 2018, the Court of Appeals (CA) reversed the NLRC decision, holding that petitioner’s multiple acts of resignation clearly demonstrated his voluntary termination of employment and that there was no basis for a constructive dismissal claim.

The petition for review on certiorari was filed under Rule 45, aiming to overturn the CA decision regarding petitioner's alleged constructive dismissal.
Upon reviewing the factual record—including multiple resignation letters and emails—the Supreme Court affirmed that petitioner's resignation was voluntary, noting that the cumulative evidence did not support allegations of coercion or harassment amounting to constructive dismissal.
The Court reiterated that while the constitutional policy provides full protection to labor, it equally supports sustaining an employer’s valid disciplinary measures when proper procedures have been followed.

Whether petitioner’s resignation was genuinely voluntary or the product of constructive dismissal resulting from an oppressive work environment.
Whether the acts and omissions of the respondents, including the administrative proceedings and the withholding of salaries, amounted to illegal dismissal.
Whether the evidence, particularly the successive resignation letters and e-mail communications, conclusively demonstrated the petitioner’s intent to sever his employment.
Whether petitioner’s claims of harassment, intimidation, and coercion were substantiated by clear, positive, and convincing evidence according to the applicable legal standards.
Whether Sitel’s handling of the disciplinary process, including the suspension and subsequent salary deductions, was justified under labor law.