G.R. No. 177114 - Penaflor vs. Outdoor Clothing Manufacturing Corp.

Manolo A. PeAaflor was hired as a probationary Human Resources Development (HRD) Manager of Outdoor Clothing Manufacturing Corporation on September 2, 1999.
On March 13, 2000, more than six months after his hiring, PeAaflor learned that the company’s President, Nathaniel Syfu, had appointed Edwin Buenaobra as the concurrent HRD and Accounting Manager.
PeAaflor perceived Buenaobra’s appointment as discriminatory and contrary to his expectations, contributing to a hostile work environment.

Frustrated by the discriminatory treatment and what he considered a forced removal from his position, PeAaflor tendered his irrevocable resignation effective at the close of office on March 15, 2000.
Believing his resignation to be a consequence of constructive dismissal, PeAaflor filed an illegal dismissal complaint with the labor arbiter.
The labor arbiter ruled in PeAaflor’s favor on August 15, 2001, finding that he had been constructively dismissed.
The National Labor Relations Commission (NLRC) reversed the labor arbiter’s decision on September 24, 2002, a ruling that was later affirmed by the Court of Appeals (CA).

The primary factual dispute centered on whether PeAaflor’s resignation was filed before or after the appointment of Buenaobra.

PeAaflor claimed that he submitted his resignation letter on March 15, 2000, as a response to the appointment.
Outdoor Clothing contended that the resignation was tendered on March 1, 2000.

In support of its version of events, Outdoor Clothing presented three memoranda:

A March 1, 2000 memorandum from Syfu to Buenaobra appointing the latter as concurrent HRD and Accounting Manager.
A March 3, 2000 memorandum from Buenaobra to Syfu confirming acceptance of the appointment.
A March 10, 2000 office memorandum from Syfu informing all concerned of Buenaobra’s new role.

These documents were belatedly presented only at the NLRC level and not before the labor arbiter.
There were indications that the memoranda might not have been properly transmitted or documented, thus casting doubt on their authenticity.
The timing of events and the secrecy surrounding the appointment raised inconsistencies, especially given the small company setting.

Following the January 21, 2010 ruling which reversed the CA’s decision, Outdoor Clothing filed a motion for reconsideration.
The corporation argued that:

PeAaflor’s irrevocable resignation indicated a voluntary departure.
The belatedly filed memoranda should support the claim that the resignation was not forced.
The burden of proving the involuntariness of the resignation rested on PeAaflor, and his evidence was insufficient.
The corporate officers (Syfu, Medylene Demogena, and Paul Lee) should not be held jointly and severally liable absent evidence of malice or bad faith.

Whether the resignation of Manolo A. PeAaflor from Outdoor Clothing was voluntary or constituted a constructive dismissal.

Determining the critical timeline: whether the resignation was filed before or after the appointment of Edwin Buenaobra.
Assessing the credibility and authenticity of the three memoranda presented by Outdoor Clothing.
Establishing if the hostile and discriminatory work environment sufficiently forced PeAaflor’s resignation.

Whether Outdoor Clothing’s corporate officers should be held jointly and severally liable for illegal dismissal.

Evaluating if there was any indication of malice or bad faith against the corporate officers.
Determining if liability for the wrongful termination should be extended beyond the corporate entity to include the individual officers.