Case Digest (G.R. No. 262564)
Facts:
Isabelle Francesca F. Paulino v. Sutherland Global Services, Inc. Clark, G.R. No. 262564, August 06, 2025, Supreme Court Third Division, Inting, J., writing for the Court.Petitioner Isabelle Francesca F. Paulino was hired by respondent Sutherland Global Services Philippines, Inc. (Sutherland) on September 12, 2016 as a Senior Training Specialist assigned to Sutherland’s Shaw Boulevard office. She performed well, was recognized as Best Trainer (May 2017) and designated OIC‑Training Manager. In September 2017 Paulino became pregnant and, about a week after she informed her Training Manager, Sutherland announced transfers of trainers to its Clark site effective October 2017. Paulino agreed to a temporary Clark assignment on assurances of hotel accommodation, shuttle service, and per diem; hours later she was told she would instead be assigned to Sutherland’s Tarlac office.
While pregnant Paulino performed training in Tarlac but suffered long daily commutes (about 3.5 hours each way from her Clark hotel), motion sickness, and halted the Tarlac sessions. She was later assigned to the Clark production area where, despite her condition, she was restricted from bringing a blanket and barred from certain breaks. In December 2017 Sutherland converted her temporary Clark assignment into a permanent one, with Moussa (Training Manager) warning that refusal would result in indefinite unpaid floating status; relocation allowance promised did not arrive. When Paulino sought a short hotel extension in January 2018 she was denied and told to take forced leave. She filed a medical leave in February 2018 (40 days rest) and, despite this, was placed on an “Absconding List” and had her March 15, 2018 salary withheld.
On June 28, 2018, after maternity leave and failed requests to be reassigned to Shaw so she could care for her newborn, Paulino submitted a resignation letter dated June 30, 2018 describing discrimination, stress, withheld pay, non‑disclosure of a “relocation bond,” and that she was “left with no option but to leave,” adding the phrase “without prejudice to the appropriate legal remedies which I may resort to in accordance with law.” She then filed a complaint for constructive dismissal, separation pay in lieu of reinstatement, unpaid 13th month pay, and moral and exemplary damages against Sutherland and, initially, its officers Erly Sarmiento and Aliaa Moussa.
The Labor Arbiter (LA) dismissed Paulino’s complaint for lack of merit in a June 11, 2019 Decision but awarded her proportionate 13th month pay for 2018 and ordered that Sarmiento and Moussa be dropped as parties. Paulino appealed to the National Labor Relations Commission (NLRC). The NLRC, in a September 30, 2019 Decision, reversed the LA and held that Paulino was constructively dismissed due to harsh, hostile and discriminatory treatment during pregnancy; it awarded full backwages and separation pay (total PHP 688,197.69) and found reinstatement infeasible. The NLRC denied Sutherland’s motion for reconsideration on November 28, 2019.
Sutherland petitioned the Court of Appeals (CA) via certiorari. The CA (Fifteenth Division) granted the petition, held the NLRC gravely abused its discretion, ...(Pro-only)
Issues:
- Was petitioner constructively dismissed from employment? ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)