Facts:

• Veronica B. Reyes was employed as a teacher at Kong Hua School starting August 1972.
• She went on maternity leave on August 26, 1982, which lasted until October 10, 1982.
• Due to complications from childbirth, Reyes requested an extension of her leave and later applied for an indefinite leave of absence.
• On December 21, 1982, she attempted to return to work but suffered a nervous breakdown after one day.
• Following the Christmas break, her request for another indefinite leave was denied by the school.
• On September 13, 1983, Reyes expressed her intention to resign, requesting two months' vacation pay and hoping for re-employment later.
• Her husband submitted another resignation letter on her behalf, citing her physical incapacity.
• The school paid her the requested vacation pay.
• In June 1985, after recovering, Reyes applied for reinstatement, but Kong Hua School refused.
• Reyes filed a complaint with the NLRC for reinstatement, back wages, and benefits.
• The labor arbiter dismissed her complaint, interpreting it as a claim for separation pay, which was also dismissed.
• Reyes appealed to the NLRC, which upheld the labor arbiter's decision, stating her resignation was voluntary.
• This led Reyes to seek relief from the Supreme Court.

Issue:

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Ruling:

• The Supreme Court ruled that Reyes' resignation was involuntary.
• Reyes is entitled to separation pay due to the circumstances surrounding her resignation.
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Ratio:

• The Supreme Court determined that the circumstances of Reyes' resignation indicated it was not voluntary.
• Reyes was under duress, as her resignation was influenced by the school administration's promise of priority for re-employment and the urgent need for her vacation pay.
• The Court emphasized that the school had no right to deny her indefinite leave due to her health issues stemming from childbirth complications.
• Under Article 133(b) of the Labor Code, maternity leave should be extended for illnesses related to pregn...continue reading