G.R. No. 208912 - Aquino vs. Aquino

Petitioner, Jonald O. Torreda, was hired by Investment and Capital Corporation of the Philippines on May 17, 2010, as an IT Senior Manager, with a monthly salary of ₱93,200.00.
His job responsibilities included supervising the IT staff and managing various IT projects, and he reported directly to William M. Valtos, Jr., the Officer-In-Charge of the IT Department and Group President of the Financial Service of the respondent.
Petitioner claimed he introduced reforms in IT management due to outdated systems and unproductive staff, which eventually led to conflicts with the senior management, particularly with a Senior Vice President from Pueblo De Oro Development Corporation who was attempting to interfere with departmental functions.

On January 5, 2012, petitioner attended a closed-door meeting with Valtos supposedly to discuss updates on his IT projects.
During the meeting, Valtos unexpectedly brought up an early performance appraisal—although petitioner’s scheduled appraisal was not until May 2012—and indicated that his performance would be rated poorly because of negative feedback from both the senior management and his team.
Valtos presented a prepared resignation letter, stating that if petitioner's performance were assessed at that moment, he would receive a failing grade, and warned that failure to sign would result in termination.
Despite petitioner’s refusal to sign the resignation letter at first, Valtos edited the letter. Petitioner, attempting to leave the room and later being pursued by Valtos and respondent’s legal counsel, eventually entered only his initials on the letter to signal that the document was not his formal or voluntary resignation.
Immediately thereafter, petitioner was escorted out of the building, barred from reporting to work, and his company email account was deactivated, effectively ending his employment that very day.

Six days after the incident, petitioner filed a complaint for illegal dismissal (constructive dismissal), moral and exemplary damages, and attorney’s fees before the Labor Arbiter (LA).
The respondent countered, arguing that petitioner had voluntarily resigned, asserting that petitioner’s inefficiencies as an IT manager led to dissatisfaction among staff, and even noted that a female employee resigned due to discomfort with his demeanor.
Respondent further contended that petitioner had substantially edited and voluntarily signed the resignation letter with courteous words, thus evidencing his consent.

The LA found that petitioner was constructively dismissed as Valtos admitted to presenting a prepared resignation letter and coercing petitioner by forcing him to choose between resignation and termination.
The LA highlighted discrepancies such as petitioner having no prior intention to resign, the premature performance appraisal, the immediate barring from work despite the resignation letter’s effective date being February 4, 2012, and the prompt filing of the complaint.
Accordingly, the LA ordered the respondent to reinstate petitioner with full seniority and award him backwages, along with ₱50,000.00 each for moral and exemplary damages.

The NLRC affirmed the LA’s ruling, reiterating that the test of constructive dismissal is whether a reasonable person in the employee’s position would have been compelled to resign under the circumstances.
The NLRC rejected the argument that petitioner voluntarily resigned merely by editing the resignation letter, and it upheld the awards for moral and exemplary damages—although it modified the remedy in light of irreparable strain in the employment relationship by granting separation pay in lieu of reinstatement.

In its June 13, 2016 decision, the CA reversed the NLRC ruling, holding that petitioner voluntarily resigned since he willingly signed the resignation letter after editing it, and emphasizing his managerial status and educational attainment as factors supporting his capacity to understand the situation.
The CA ruled that there was no evidence of coercion or abrogation of due process; thus, the complaint for illegal dismissal was dismissed.
Petitioner’s subsequent motion for reconsideration before the CA was denied in its February 9, 2017 resolution.

Petitioner challenged the CA ruling by arguing that the lower courts erred in their factual findings, particularly regarding the voluntariness of his resignation.
He advanced several arguments:

He was forced to resign under circumstances amounting to constructive dismissal.
The incident involved coercion—evidenced by the premature performance appraisal and Valtos’ insistence—leaving him with no viable alternative other than resigning.
The timing of events (immediate barring from the company, deactivation of his email, and filing his complaint within days) clearly supported the claim that he did not intend to abandon his job voluntarily.

Respondent, in its comment, maintained that the issues raised were of a factual nature unsuitable for a petition for review on certiorari and reiterated that petitioner’s signature on the resignation letter indicated voluntariness.
In its reply, petitioner emphasized that, even if petitioner had edited the letter, the overall circumstances contradicted the notion of a free and voluntary resignation.

Whether petitioner’s resignation was genuinely voluntary or a result of coercion amounting to constructive dismissal.

Did the circumstances surrounding the presentation and signing (or initialing) of the resignation letter demonstrate force or compulsion by the respondent?
Do the pre-resignation and post-resignation facts (e.g., the untimely performance appraisal, company actions immediately following the incident, and petitioner’s immediate filing of a complaint) support a finding of involuntary resignation?

Whether the Court of Appeals erred in reversing the decisions of the Labor Arbiter and the NLRC based on its evaluation of the factual record.

Was it proper for the CA to disregard substantial evidence and conflicting factual findings from the lower courts?
Did the CA mistake the act of petitioner's editing of the resignation letter as evidence of voluntary resignation?

Whether the respondent failed to provide a just cause for the termination, given that the proper grounds under Article 282 of the Labor Code were not validated by substantial evidence.

Is the respondent’s assertion of managerial ineffectiveness and loss of trust supported by credible and substantial evidence?

Whether the award of moral and exemplary damages should stand, given the lack of compelling evidence showing that the dismissal was conducted in bad faith, or in a wanton, oppressive, or malevolent manner.