Case Summary (G.R. No. 236161)
Background and Timeline of Events
Lugawe’s employment with PCRI began on March 9, 2000, and she was promoted to her HR Officer/Manager role on January 1, 2007. Following the restructuring brought on by the acquisition by FILSYSTEMS, key HR functions were removed from her responsibilities. Lugawe argued that these changes led to her constructive dismissal, which she characterized as a violation of her rights, including non-payment of separation pay and damages.
Petitioner’s Claims
Lugawe alleged that her authority and responsibilities were significantly diminished when crucial HR functions were transferred to the Finance Department. She contended these actions were deliberate and aimed at forcing her out of her position, particularly as she was no longer able to manage critical HR functions effectively. Lugawe compiled a list of grievances stemming from what she perceived as retaliatory and abusive treatment by her superiors, which included accusations of incompetence and disregard for her contributions.
Respondent’s Defense
PCRI defended itself by asserting that Lugawe was not constructively dismissed but had abandoned her position following her failure to return to work after a sick leave. The company claimed that it executed valid management prerogatives in transferring the HR functions to enhance operational efficiency, maintaining that there was neither a reduction in rank nor a decrease in pay for Lugawe.
Labor Arbiter’s Ruling
In the initial ruling by the Labor Arbiter on June 30, 2014, it was found that Lugawe was indeed constructively dismissed given that the stripping of her essential duties and the resultant loss of authority to perform her job effectively amounted to illegal dismissal. The Labor Arbiter ordered PCRI to pay Lugawe backwages, separation pay, attorney's fees, and moral damages.
National Labor Relations Commission (NLRC) Decision
Upon appeal by PCRI, the NLRC upheld the Labor Arbiter’s ruling on November 28, 2014. The NLRC reaffirmed the constructive dismissal finding and adjusted the amount of damages due to Lugawe, reducing the total compensation assessed by the Labor Arbiter but still concluding that her dismissal was unjust.
Court of Appeals’ Ruling
PCRI subsequently petitioned the Court of Appeals (CA). In a significant turn, the CA reversed the NLRC's decision on April 6, 2017, asserting that substantial evidence was lacking to support Lugawe's claims of constructive dismissal. The CA determined that Lugawe voluntarily resigned, essentially denying her eligibility for the separation pay and damages awarded by the NLRC. Further, the CA directed Lugawe to return the amounts previously granted.
Petitioner’s Arguments on Review
In her Petition for Review on Certiorari, Lugawe raised several errors attributed to the CA, including a misassessment of evidence and the conclusion that she had voluntarily resigned. She contended that the CA overstepped its authority by re-evaluating facts already established by the Labor Arbiter and NLRC based on substantial evidence.
Supreme Court’s Resolution
The Supreme Court ultimately denied Lugawe's petition, sustaining the CA's findings. The Court c
...continue readingCase Syllabus (G.R. No. 236161)
Case Background
- The case involves a Petition for Review on Certiorari filed by Alma C. Lugawe against Pacific Cebu Resort International, Inc. (PCRI), seeking to reverse the decision of the Court of Appeals (CA) which overturned the earlier rulings of the National Labor Relations Commission (NLRC) and the Labor Arbiter (LA).
- Lugawe claimed constructive dismissal from her employment with PCRI, along with non-payment of separation pay and damages.
- The CA ruled that Lugawe voluntarily resigned, contrary to her claims of constructive dismissal.
Employment History
- Lugawe was hired by PCRI as an Accounting Clerk on March 9, 2000, and was promoted to HR Officer/Manager on January 1, 2007.
- In October 2013, PCRI underwent a takeover by FILSYSTEMS, which included an agreement to maintain the employment status and benefits of its employees.
Allegations of Constructive Dismissal
- Lugawe claimed that following the takeover, significant HR functions were removed from her role, effectively reducing her to a mere office clerk.
- Functions such as payroll processing and employee attendance monitoring were transferred to other departments, and she lost one of her HR assistants.
- Lugawe alleged that she was subjected to disdainful treatment by her superiors and was excluded from critical decision-making processes.
Initial Complaint and Employer’s Defense
- On December 13, 2013, after a sick leave, Lugawe filed a complaint for constructive dismissal, asserting her right to s