Case Digest (G.R. No. 245269)
Facts:
Saudi Arabian Airlines v. Maria Lourdes D. Castells and Shalimar Centi-Mandanas, G.R. No. 245269, July 28, 2025, Supreme Court Third Division, Dimaampao, J., writing for the Court. Petitioner is Saudi Arabian Airlines (Saudia); respondents are flight attendants Maria Lourdes D. Castells and Shalimar Centi-Mandanas (Bilbao is a related employee whose separate case is discussed in the record).Castells, Bilbao and Centi-Mandanas were hired as flight attendants by Saudia on May 13, 1986. On August 18, 2004 Saudia’s head office issued an inter-office memorandum directing the transfer of several Manila-based flight attendants, including the three, to Jeddah effective September 1, 2004 for "operational requirements." Castells submitted a resignation dated September 1, 2004, accepted effective September 30, 2004; Bilbao and Centi-Mandanas tendered resignations on September 7, 2004. The three later executed quitclaims on October 28, 2004 acknowledging receipt of end-of-service award and final settlement, and waiving further claims; Bilbao signed Castells’s quitclaim on her behalf.
Between July and August 2005 Castells, Bilbao and Centi-Mandanas filed complaints for illegal constructive dismissal against Saudia and its Manila-based manager Saddik, alleging they were forced to resign after being transferred to Jeddah and that transfers were a scheme to push out older employees. Saudia maintained the resignations and quitclaims evidenced voluntary separations and argued that allowing repudiation would amount to unjust enrichment.
The Labor Arbiter (Labor Arbiter Ramon Valentin C. Reyes) rendered an August 31, 2006 Decision declaring the complainants illegally dismissed and ordering backwages, separation pay and attorney’s fees. The National Labor Relations Commission (Third Division) reversed in two Resolutions (June 25, 2007 and October 26, 2007), finding resignation and quitclaims showed voluntary separation and dismissing the complaint. Respondents sought certiorari relief before the Court of Appeals in CA-G.R. SP No. 101971; the Court of Appeals (Ninth Division) in its July 27, 2017 Decision reversed the NLRC, reinstated the Labor Arbiter’s Decision as to Castells and Centi-Mandanas and awarded moral and exemplary damages; its February 15, 2019 Resolution denied reconsideration. Saudia filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, docketed G.R. No. 245269, which is the subject of this decision.
The record also includes a parallel case involving Bilbao (CA-G.R. SP No. 102319), which the Court of Appeals decided May 30, 2008 and this Court affirmed in G.R. No. 183915 (December 14, 2011), finding Bilbao voluntarily resigned. The Supreme Court’s present review considered those prior rulings and multiple pre...(Pro-only)
Issues:
- Under Rule 45, may the Supreme Court review the factual findings of the labor tribunals in this case?
- Were respondents Maria Lourdes D. Castells and Shalimar Centi-Mandanas constructively dismissed, or did they voluntarily resign?
- Are respondents entitled to moral and exemplary damages give...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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