Title
Philippine Airlines, Inc. vs. National Labor Relations Commission
Case
G.R. No. 102411
Decision Date
Aug 10, 1993
A robbery on a Manila-bound PAL flight implicated security guards and employees. Resigned confessing theft, later challenged as coerced; SC upheld voluntary resignation, dismissing illegal termination claims.
Font Size:

Case Digest (G.R. No. 102411)

Facts:

Background of the Case

The case originated from a robbery involving a Japanese national, Akira Saikyo, who was a passenger on a Philippine Airlines (PAL) flight bound for Singapore on November 13, 1984. While the aircraft was still at the Manila International Airport, Saikyo's attache case was forcibly opened, and Y500,000.00 and US$400.00 were stolen.

Involvement of Security Guards

Vilma Saludario, a security guard from Lanting Security and Watchman Agency (LSWA), which was contracted by PAL, testified that another security guard, Francis P. Dagui, visited her residence on the same day and left some foreign currency with her. Dagui later retrieved the money. Another LSWA guard, Dumpit, reported seeing Dagui counting dollar bills, which led to an investigation.

Confession and Implication of PAL Employees

Dagui confessed to possessing Y200,000.00, which he claimed was part of his share from the robbery. He implicated several PAL employees, including Dominador Zapanta, Cesar Lopez, Edgardo Ferrer, and Wilfredo Omar, stating that they also received shares of the stolen money. A plan was devised to entrap Dagui, leading to his arrest and the recovery of P8,550.00 from him.

Resignation of Employees

On November 26, 1984, Dagui, Zapanta, Lopez, Ferrer, and Omar signed a joint resignation letter, admitting their involvement in the theft and voluntarily resigning from their positions at PAL. The resignation was accepted on January 12, 1985, with forfeiture of separation benefits and prejudice to future re-employment.

Filing of Complaint

On January 14, 1986, Ferrer and Zapanta filed a complaint with the National Labor Relations Commission (NLRC), alleging that they were coerced into signing the resignation letter and were dismissed without due process. The complaint was dismissed for Lopez and Omar due to lack of interest, but proceeded for Ferrer and Zapanta.

Labor Arbiter and NLRC Decisions

The Labor Arbiter ruled in favor of Ferrer and Zapanta, ordering their reinstatement with backwages and attorney’s fees. The NLRC affirmed this decision, finding that PAL failed to prove the voluntariness of the resignation and did not provide due process.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Voluntariness of Resignation: The Court found that the resignation was voluntary based on the sworn statements of the employees and the testimony of PAL’s security agent, Amando Garcia, who witnessed the execution of the resignation letter. The Court rejected the claim of coercion, noting that the employees had ample opportunity to contest the resignation but chose not to do so until over a year later.

  2. Due Process: The Court held that PAL complied with due process. The employees were investigated, admitted their involvement in the theft, and voluntarily resigned. The Court also noted that the employees’ union, PALEA, did not pursue an administrative investigation, further supporting the conclusion that the resignation was voluntary.

  3. NLRC’s Grave Abuse of Discretion: The Court found that the NLRC disregarded relevant evidence and engaged in strained reasoning to justify its decision. The Court emphasized that the NLRC’s findings were inconsistent with the facts and the law, warranting the nullification of its decision.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.