Case Summary (G.R. No. 175481)
Factual Antecedents
MOL Philippines, Inc., a common carrier, employed the petitioners in various roles between 1997 and 1997. In October and November of 2002, Otarra, Auza, and Jeanjaquet voluntarily resigned, accepting separation benefits and executing quitclaims. Approximately 15 months later, they filed separate complaints for illegal dismissal, claiming they were misled into resigning due to management’s coercive tactics, even though they had accepted severance benefits.
Proceedings before the Labor Arbiter
In May 2004, the Labor Arbiter directed both parties to submit Position Papers. The respondents contended that the petitioners voluntarily resigned, thus barring further claims. The petitioners, however, indicated that they were forced to resign under duress from management's misrepresentation about job security, prompting complaints of constructive dismissal. The Labor Arbiter eventually dismissed their complaints due to late submission of the Position Paper, ruling that the late filing constituted a failure to prosecute.
Proceedings before the National Labor Relations Commission
Petitioners appealed the dismissal to the NLRC, which determined that the petitioners' late Position Paper filing should be allowed as the delay was justifiable. The NLRC then found that the quitclaims and resignations were done under duress and ruled in favor of the petitioners, granting them reinstatement, back wages, and damages.
Proceedings before the Court of Appeals
Respondents sought a review from the Court of Appeals, which granted a temporary restraining order against the NLRC's decision and ultimately annulled it, ruling that the resignation letters indicated voluntary separation. The appellate court did not address the issue of the NLRC's jurisdiction. This ruling was subsequently challenged by the petitioners.
Issues
Petitioners claimed that the CA erred in concluding that they voluntarily resigned, as they asserted that their resignations resulted from management coercion and misrepresentation. They further contended that their quitclaims should be invalidated due to coercion, and that the CA failed to recognize evidence supporting their claims of constructive dismissal.
Our Ruling
The Supreme Court found no merit in the petitioners' assertions. It upheld that the NLRC had jurisdiction to entertain their appeal and ruled that there was no abuse of discretion in the Labor Arbiter’s
...continue readingCase Syllabus (G.R. No. 175481)
Background and Procedural History
- The case revolves around the petitioners, Dionisio F. Auza, Jr., Adessa F. Otarra, and Elvie Jeanjaquet, who filed a petition for review on certiorari against MOL Philippines, Inc. and its President, Cesar G. Tiutan.
- The petition contests the decisions of the Court of Appeals (CA) dated August 17, 2006, and the resolution dated November 15, 2006, which reversed the earlier findings of the National Labor Relations Commission (NLRC) regarding illegal dismissal claims.
- The CA's decision dismissed the complaints for illegal dismissal initiated by the petitioners against the respondents.
Factual Antecedents
- Respondent MOL is a common carrier that employed Auza and Jeanjaquet on October 1, 1997, and Otarra on November 1, 1997.
- The petitioners voluntarily resigned: Otarra on October 14, 2002, and Auza and Jeanjaquet on October 30, 2002, all while receiving various separation benefits and signing quitclaims.
- Almost 15 months post-resignation, the petitioners filed separate complaints for illegal dismissal, which were consolidated.
Labor Arbiter Proceedings
- The Labor Arbiter directed the parties to submit position papers, where respondents argued that the petitioners voluntarily resigned and executed quitclaims, thereby barring further claims.
- The petitioners, later represented by a new lawyer, argued their resignations were induced by misrepresentation regarding the closure of their Cebu branch.
- The Labor Arbiter dismis