G.R. No. 222980 - Rodriguez vs. Park N Ride, Inc.

Lourdes C. Rodriguez was employed beginning January 30, 1984, initially as a Restaurant Supervisor at Vicest Philippines Inc., later transferred to administrative and finance duties after the restaurant business closed.
She handled personnel and administrative matters of multiple companies owned by the Javier spouses (Vicente and Estelita), including Buildmore Development and Construction Corporation, Asset Resources Development Corporation, Grand Leisure Corporation, and Park N Ride Inc.
Rodriguez was also tasked with household concerns of the spouses, such as payrolls for household staff and safeguarding their house during travels abroad.
She worked long hours, from 8:00 a.m. to 7:00 p.m., Mondays to Saturdays, was on call on Sundays, and worked during holidays without corresponding additional compensation.
Rodriguez’s salary was subject to deductions for absences, and she was allegedly not paid service incentive leave pay.

Circumstances Leading to Resignation and Allegations of Constructive Dismissal

Rodriguez claimed her working conditions became unbearable, citing unreasonable and hot-headed behavior from Estelita Javier, who allegedly belittled and embarrassed her before co-workers.
On September 22, 2009, after a disagreement due to the late opening of the office, Estelita reportedly told Rodriguez, “Kung ayaw mo na ng ginagawa mo, we can manage!” which Rodriguez claimed pushed her to resign.
Rodriguez wrote a letter on September 26, 2009, complaining about constant fault-finding aimed at forcing her resignation.
Her resignation was allegedly not accepted initially; however, on October 6, 2009, the Javier spouses acknowledged it.
Rodriguez filed a complaint on October 7, 2009, for constructive dismissal, unpaid service incentive leave pay, 13th month pay, and moral and exemplary damages.

The Javier spouses emphasized their trust and confidence in Rodriguez, citing her seniority and the sensitive nature of tasks assigned to her, including custody of financial documents and authority to transact with banks.
They characterized Rodriguez as emotionally sensitive and prone to “tampo” (sulking) and absences following reprimands.
Rodriguez had tendered resignations prior to 2009 but did not pursue them.
After concerns about unliquidated cash advances and missing company checkbooks arose, the spouse’s trust in Rodriguez diminished.
Rodriguez allegedly failed to liquidate cash advances amounting to over P6 million and deposited company checks into her personal account without authorization.
The spouses denied the claims of moral and exemplary damages and asserted willingness to pay 13th month pay differentials upon completion of clearance requirements.

The Labor Arbiter dismissed Rodriguez’s complaint, finding her resignation was voluntary and not due to hostile conditions.
The National Labor Relations Commission (NLRC) initially reversed this, ruling illegal dismissal and awarding benefits and damages but later reinstated the Labor Arbiter’s dismissal upon reconsideration.
Rodriguez’s motion for reconsideration was denied by the NLRC.
The Court of Appeals ruled no illegal dismissal but ordered payment of service incentive leave pay and 13th month pay for 2006 to 2009 with legal interest and attorney’s fees.
Rodriguez filed a petition for review before the Supreme Court contesting non-recognition of constructive dismissal and the limitation of service incentive leave pay to three years.

Whether Lourdes C. Rodriguez was constructively dismissed.
Whether Rodriguez is entitled to full service incentive leave pay for her entire 25 years of service or limited to a three-year prescriptive period.
Whether Rodriguez is entitled to moral and exemplary damages due to alleged inhumane treatment by her employers.