Case Digest (G.R. No. 234575)
Case Digest (G.R. No. 234575)
Facts:
Renato C. Tacis and Dionicio Lamis III v. Shields Security Services, Inc., Teresita Soliman and Dioneffel Morante, G.R. No. 234575, promulgated July 07, 2021, Supreme Court Third Division, Hernando, J., writing for the Court.Petitioners Renato C. Tacis and Dionicio Lamis III (together with a co-complainant) filed a complaint for illegal dismissal and claims for full backwages, separation pay in lieu of reinstatement, and salary differentials against respondent employer Shields Security Services, Inc. and its officers Teresa Soliman (President) and Dionefel Morante (General Manager). Tacis alleged hire on April 4, 2007 and Lamis on May 1, 2012, both assigned as regular security guards at the Texas Instruments post in Baguio City earning P280 per day.
In November 2013 the Company deployed roughly 15 new guards at Texas Instruments and instructed petitioners to train them for three days. On November 29, 2013 Morante allegedly informed petitioners they were relieved and terminated because the client requested replacements; he handed them checks described as "retirement pay" and promised remaining benefits upon return to Manila. Morante also allegedly promised transfer to a sister company, Soliman Security Services, and had petitioners complete forms in anticipation of absorption. Trusting that promise, petitioners executed handwritten resignation letters and quitclaims to receive separation pay, 13th month pay, last salary and other benefits.
When the promised transfer did not materialize, petitioners filed the complaint before the NLRC Regional Arbitration Branch in Baguio claiming constructive (illegal) dismissal. Respondents countered that petitioners voluntarily resigned—supported by their handwritten resignation letters, exit paperwork, acceptance of monetary benefits, and executed Quitclaim, Release and Waiver—and that deductions for a death mutual aid fund were authorized by petitioners' signed Statement of Understanding and Participation.
On August 22, 2014, Labor Arbiter Monroe C. Tabingan found constructive dismissal and ordered respondents jointly and severally to pay separation pay, full backwages (less prior benefits), refund of death mutual aid deductions, and attorney’s fees (totaling P276,748.66). The Arbiter concluded the replacement of regular employees without cause and the promise of transfer that never happened amounted to dismissal in disguise; the resignation letters were pro forma and involuntary.
On appeal, the National Labor Relations Commission (NLRC) reversed on November 10, 2014, ruling that petitioners voluntarily resigned—pointing to expressions of gratitude in their letters, the executed quitclaims, processing of resignation exit documents, and absence of proof of coercion or deception—and dismissed the complaint for lack of merit. The NLRC also denied petitioners’ motion for reconsideration in a resolution dated March 16, 2015.
Petitioners then filed a Petition for Certiorari under Rule 65 with the Court of Appeals (CA), asserting grave abuse of discretion by the NLRC in finding no illegal dismissal. The CA, in a decision dated April 20, 2017, denied the petition and affirmed the NLRC, emphasizing petitioners’ failure to present corroborating evidence that their consent was vitiated and upholding the validity of the resignation letters and quitclaims; the CA denied reconsideration in a September 26, 2017 resolution.
Petitioners elevated the case to the Supreme Court by a Petition for Review on Certiorari under Rule 45, challenging (1) whether the CA gravely erred in affirming the NLRC that there was no illegal dismissal and (2) whether the CA gravely erred in denying their monetary claims.
Issues:
- Did the Court of Appeals gravely err in affirming the NLRC's conclusion that petitioners were not illegally (constructively) dismissed?
- Did the Court of Appeals gravely err in affirming the NLRC's denial of petitioners' monetary claims?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)