Case Summary (G.R. No. 100127)
Background of the Case
On December 16, 1996, Elena's daughter underwent a caesarian section, prompting Elena to take a leave of absence. Upon her return to work on December 23, 1996, she was informed by Elsa Co, co-manager of Fortuny Garments, that she was considered 'too old' to continue working, followed by a claim of dismissal due to her absence. Elena contested this, arguing she was unlawfully terminated, not voluntarily resigned.
Legal Proceedings
Elena filed a complaint against Fortuny Garments and Johnny Co asserting her illegal dismissal and demanding unpaid salaries, overtime pay, and other benefits. The Labor Arbiter ruled against her, determining she had voluntarily resigned. This decision was grounded in the rationale that her leave of absence, motivated by family obligations, signified her resignation rather than dismissal.
Labor Arbiter’s Decision
The Labor Arbiter cited a cash voucher signed by Elena as evidence of her voluntary resignation, alongside claims of her well treatment during her employment. However, Elena contested the authenticity and circumstances of her signature, alleging that she was pressured into signing blank vouchers for different purposes. The Arbiter ultimately dismissed her claims for monetary compensation, asserting that resignation carries a forfeiture of entitlements unless specified otherwise in company policy.
Appeal to the NLRC and CA
Elena appealed the Arbiter's decision to the National Labor Relations Commission (NLRC), which upheld the Arbiter’s ruling. Frustrated, she sought a remedy from the Court of Appeals (CA), which subsequently ruled in her favor, asserting that the evidence presented did not substantiated claims of voluntary resignation.
Petitioner’s Arguments
Johnny Co filed a motion for reconsideration post-CA decision, arguing that the appellate court had displaced the factual findings of the lower courts with speculative assertions. He insisted that Elena's resignation was evidenced by the cash voucher, which indicated her acceptance of separation pay.
Court’s Analysis
The Supreme Court examined the validity of the resignation assertion, emphasizing that resignation must be an unconditional act coupled with an intent to relinquish employment. The Court noted discrepancies in the evidence
...continue readingCase Syllabus (G.R. No. 100127)
Case Background
- The case involves a petition for review on certiorari against the Decision of the Court of Appeals (CA) in CA-G.R. SP No. 56153.
- The respondent, Elena J. Castro, had been employed as a sewer by Fortuny Garments Corporation since 1985, with Johnny Co. serving as the company's president.
- Elena was compensated for her work until December 21, 1996, when she took a leave of absence due to her daughter’s caesarean delivery on December 16, 1996.
Events Leading to Dispute
- Upon her return to work on December 23, 1996, Elena was informed by Elsa Co, the co-manager and wife of Johnny Co, that she could not continue working as she was "already old."
- Despite her insistence on her capability to work, she was dismissed under the pretext of failing to report for work after her leave.
- Following her dismissal, Elena filed a complaint against Fortuny Garments and Johnny Co for illegal dismissal and unpaid monetary benefits.
Petitioner’s Defense
- Petitioner Johnny Co contended that Elena had voluntarily resigned, citing a cash voucher dated January 30, 1996, as evidence of her resignation.
- The petitioner asserted that Elena had received all her salary, benefits, and bonuses and therefore had no grounds for her complaint.
Labor Arbiter’s Decision
- On December 21, 1998, the Labor Arbiter ruled in favor of the petitioner, stating that Elena had volun