Case Summary (G.R. No. 64374)
Events Leading to Resignation
Custodio's resignation letter announced a one-month vacation followed by an irrevocable resignation after serving a 30-day notice. The board of directors deferred action on his resignation in their meeting on May 8, 1981, leading to a request for him to explain his decision in a subsequent meeting on May 13, 1981. At this meeting, Custodio expressed his intention to withdraw his resignation, a claim supported by recorded minutes of the meeting.
Actions Following Resignation
Despite his verbal withdrawal, discussions regarding his resignation continued at the board meeting on May 30, 1981. It was reiterated that his resignation was irrevocable; however, Custodio had returned from his vacation and filed a complaint for illegal dismissal shortly thereafter, indicating his belief that he was still an employee.
Legal Proceedings
Custodio's complaint was filed with the Ministry of Labor and Employment (MOLE) on June 10, 1981, claiming unlawful dismissal. The investigating officer recommended his reinstatement, but this was dismissed by the Assistant Regional Director in August 1981. Despite attempts by Custodio to appeal this decision, the Deputy Minister upheld the dismissal, prompting Custodio's petition to the higher courts.
Court's Consideration of Resignation Validity
The crux of the case revolved around whether Custodio's resignation was effective or if he had successfully withdrawn it. The Solicitor General supported Custodio's position, citing acts that indicated his intention to retract his resignation, including the absence of a formal notice period and his reporting back to work.
Conclusion on Resignation's Effectiveness
The court determined that, despite the "irrevocable" label in his resignation letter, the facts indicated that both Custodio and the board treated the resignation as not yet effective due to his verbal withdrawal at the May 13 meeting. This indica
...continue readingCase Syllabus (G.R. No. 64374)
Case Overview
- The case is a labor dispute involving Victor A. Custodio, who was employed by First Farmers Milling and Marketing Cooperative Association, Inc. for nearly 17 years.
- Custodio held the position of Assistant General Manager for Operations, earning a substantial annual income with various allowances and bonuses.
- The dispute arose following a contentious decision regarding the purchase of a boiler, leading to allegations of corruption and ultimately Custodio's resignation.
Background of the Case
- Custodio submitted his resignation letter on May 5, 1981, citing a need for vacation and an intention to resign irrevocably after a 30-day notice.
- The resignation letter sparked internal conflicts, particularly regarding the selection of a boiler, which led to accusations of kickbacks among board members and suppliers.
- The board of directors deferred action on Custodio's resignation in a meeting held on May 8, 1981.
Withdrawal of Resignation
- During a board meeting on May 13, 1981, Custodio expressed his desire to withdraw his resignation, promising to submit a formal letter to that effect.
- Despite this verbal withdrawal, the board's subsequent discussions and decisions indicated a belief that his resignation was irrevocable.
- On May 30, 1981, the board noted that Custodio had expressed intentions to withdraw his resignation but di