Case Summary (G.R. No. 76728)
Petitioner and Respondent
• Petitioners: Security guards who allege underpayment of wages and benefits and constructive dismissal
• Respondent: CORPS, their employer, accused of misrepresenting payments to induce resignations and quitclaims
Key Dates
• Hire Dates: October 20, 2005 to February 2010
• Request for Assistance (SEnA): January–March 2015
• Labor Arbiter Decision: August 28, 2015
• NLRC Resolutions: December 29, 2015; February 24, 2016
• CA Consolidated Decision: February 15, 2018
• Supreme Court Decision: April 3, 2024
Applicable Law
• 1987 Constitution (labor rights, due process)
• Labor Code of the Philippines, as amended by RA 10396 (mandatory conciliation-mediation under Single-Entry Approach)
• New Civil Code (Articles 6, 22 on public policy and unjust enrichment)
Facts
• Petitioners worked 12-hour shifts daily, including holidays and rest days, without proper premium pay, 13th-month pay, service incentive leave pay, ECOLA, and without full social security and housing contributions.
• Monthly deductions of PHP 200–1,000 for “trust fund savings” and PHP 200 for cash bond.
• In SEnA conferences (March 3 and 10, 2015), CORPS offered to pay only trust fund and cash bond, conditioned on submission of resignation letters and quitclaims. Petitioners signed, relying on assurances that remaining money claims would follow.
• After receipt of limited payment, petitioners were prevented from resuming work and never received the balance of their claims.
Proceedings Before the Labor Arbiter and NLRC
• April 2015: Petitioners filed consolidated complaints for unpaid wages, benefits, and constructive dismissal.
• CORPS filed perjury complaints for alleged forum shopping; dismissed for lack of evidence (September 8, 2017).
• Labor Arbiter (LA) dismissed petitioners’ complaints (August 28, 2015), upholding voluntary resignations and quitclaims.
• NLRC granted petitioners’ appeal (December 29, 2015), finding no intent to resign and voiding quitclaims due to uncertainty of claims; remanded to LA to compute monetary awards; denied reconsideration (February 24, 2016).
Proceedings Before the Court of Appeals
• CA consolidated certiorari petitions of both parties.
• CA upheld NLRC resolutions (February 15, 2018), ruling:
– No forum shopping, as SEnA is mandatory and non-adjudicatory.
– Resignation letters and quitclaims were voluntary under assurances.
– No illegal dismissal; remand to LA proper for money claims.
• Petitioners’ motion for reconsideration denied (November 8, 2018).
Issues
- Whether petitioners committed forum shopping.
- Whether quitclaims executed under SEnA are valid and binding.
- Whether petitioners were constructively dismissed and thus entitled to backwages, damages, and attorney’s fees.
Forum Shopping
• Elements: identity of parties; of rights asserted; of reliefs such that judgment in one bars the other (res judicata).
• SEnA settlement is administrative, non-judicial, non-final, and a prerequisite to NLRC filing.
• No res judicata from unfulfilled SEnA agreement; mandatory conciliation-mediation under Art. 234, Labor Code.
• Conclusion: No forum shopping.
Validity of Quitclaims
• Labor jurisprudence disfavors quitclaims that exempt employers from liability and require workers to relinquish rights, void as contrary to public policy and New Civil Code Art. 22.
• Valid quitclaims must be voluntary, informed, with credible consideration, and not procured by fraud or unconscionable terms.
• Here, quitclaims were procured by misrepresentations that remaining money claims would follow.
• Minutes of Proceedings confirm pending claims.
• Conclusion: Quitclaims void ab initio for fraud and uncertainty; do not bar further claims.
Constructive Dismissal
• Definition: termination by employer’s acts making continued employment impossible or intolerable, compelling resignation; burden of proving voluntary resignation rests on employer.
• Petitioners signed resignation letters under false assurances of full payment.
• CORPS prevented resumption of work despite unfulfilled promises.
• Case law: involuntary resignations (by deception, intimidation, or intolerable conditions) constitute constructive dismissal (Doble v. ABB, Torreda, SHS Perforated Materials, Al-Masiya).
• Conclusion: Petitioners were constructively dismissed.
Entitlements and Damages
• Illegally dismissed employees are entit
Case Syllabus (G.R. No. 76728)
Facts
- Petitioners Domingo Naldo, Jr., Rogelio Benitez, Isidro Alfonso, Jr., Ronaldo Ledda, Bernardo Fabulare, Armando De Luna, and Nelson Villacentino served as security guards of Corporate Protection Services, Phils., Inc. (CORPS) in Tarlac and Cabanatuan City.
- Their hiring dates ranged from October 20, 2005 to February 2010, with monthly salaries between ₱15,000.00 and ₱15,300.00.
- Petitioners alleged underpayment and unauthorized deductions of ₱200–₱1,000 per month for a “trust fund savings” and ₱200 per month as a cash bond.
- They were required to work 12 hours daily, including rest days and holidays, but claimed non-payment of overtime, holiday pay, rest day premium, service incentive leave pay, 13th-month pay, ECOLA, and statutory contributions.
- In January 2015, they filed a Request for Assistance (RFA) under DOLE’s Single-Entry Approach (SEnA) before the NCMB, seeking unpaid wages, benefits, and contributions.
- On March 3, 2015, CORPS offered payment only for trust fund savings and cash bonds; petitioners refused in order to pursue all claims.
- On March 10, 2015, petitioners were asked to sign resignation letters and pro forma quitclaims in exchange for “full” payment; they signed and received the same checks previously offered.
- Minutes of Proceedings confirmed that other monetary claims were still under validation and reconciliation by management.
- Petitioners were prevented from returning to work and, by end-March 2015, had not received any further payments.
Proceedings Before the Labor Arbiter and the NLRC
- On April 14, 2015, Naldo filed a complaint for non-payment of various wages, benefits, separation pay, moral and exemplary damages, and attorneys’ fees; the other petitioners filed similar complaints on May 4, 2015, later consolidated and amended to include constructive dismissal.
- CORPS filed a perjury Complaint-Affidavit against petitioners for alleged forum shopping; the City Prosecutor dismissed it for insufficiency of evidence on September 8, 2017.
- The Labor Arbiter (LA) dismissed petitioners’ complaints on August 28, 2015, holding that resignations and quitclaims were voluntarily executed and that the SEnA settlement must be respected.
- Petitioners appealed. On December 29, 2015, the NLRC:
- Held that petitioners had no intention to resign;
- Found no illegal dismissal (no actual termination by CORPS);
- Declared the quitclaims invalid due to uncertainty of the underlying money claims;
- Ordered petitioners to return to work and remanded monetary claims to the LA.
- Motions for reconsideration by both parties were denied by the NLRC on February 24, 2016.
Proceedings Before the Court of Appeals
- Petitioners and CORPS separately filed Petitions for Certiorari (CA-G.R. SP No. 144925 and CA-G.R. SP