Facts:

The case involves Veronica B. Reyes as the petitioner and the National Labor Relations Commission (NLRC) and Kong Hua School as the respondents. The events leading to the case began in August 1972 when Reyes commenced her employment as a school teacher at Kong Hua School. On August 26, 1982, she went on maternity leave, which lasted until October 10, 1982. Due to complications from childbirth, Reyes requested an extension of her leave and subsequently applied for an indefinite leave of absence until she was fit to return to work. On December 21, 1982, she attempted to resume her duties but was only able to teach for one day before suffering a nervous breakdown. Following the Christmas break, she again sought an indefinite leave of absence due to her health issues, but this request was denied by the school administration.

On September 13, 1983, upon the advice of the school principal, Reyes submitted a letter expressing her intention to resign while also requesting her two m...

Facts:

Employment and Maternity Leave

• Petitioner Veronica B. Reyes started teaching at Kong Hua School in August 1972.
• She went on maternity leave from August 26 to October 10, 1982, due to complications from childbirth.
• She requested an indefinite leave extension due to poor health but was only able to teach for one day on December 21, 1982, before suffering a nervous breakdown.
• After the Christmas vacation, she applied for another indefinite leave, which was disapproved by the school.

Resignation and Vacation Pay

• On September 13, 1983, Reyes submitted a resignation letter, advised by the school principal, in exchange for her two months' vacation pay for April-May 1982.
• The resignation letter included conditions: she would be given priority for re-employment and considered an old employee, not a new hire, upon her return.
• Two weeks later, her husband signed another resignation letter on her behalf, stating her resignation was effective October 15, 1982, due to her physical incapacity to teach.
• The school paid her two months' vacation pay.

Reinstatement Attempt and Complaint

• In June 1985, Reyes, having regained her health, applied for reinstatement, but the school refused.
• She filed a complaint with the NLRC for reinstatement, backwages, and other benefits.
• The Labor Arbiter treated her complaint as a claim for separation pay and dismissed it.
• The NLRC upheld the dismissal, ruling that her resignation was voluntary.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Involuntary Resignation: The resignation was not voluntary but coerced by the school's refusal to grant her indefinite leave and its promise of re-employment. The circumstances, including her illness and financial need, rendered her resignation involuntary.
2. Illegal Dismissal: The school's refusal to rehire her, despite its prior promise, constituted illegal dismissal.
3. Entitlement to Backwages and Separation Pay: Under Article 284 of the Labor Code, an employee dismissed for health reasons is entitled to separation pay. Since the school forced her to resign to avoid this obligation, she is entitled to backwages and separation pay.
4. Reinstatement: The petitioner is entitled to reinstatement to her former position without loss of seniority, rank, or benefits. If reinstatement is not feasible, she is entitled to separation pay in addition to backwages.