Case Summary (G.R. No. 206316)
Background of the Case
John Peckson was employed by Panasonic as a Sales Supervisor. He submitted two resignation letters in 2003, the first intended to take effect on October 30, 2003, and the second, dated September 25, 2003, changing the effective date to October 15, 2003. In 2005, Peckson filed a complaint for constructive dismissal, claiming he was coerced into resigning due to accusations of forgery by Jose De Jesus, his manager. The Philippine National Police Crime Laboratory findings supported Peckson's assertions, leading him to believe he was wrongfully treated.
Labor Arbiter and NLRC Proceedings
The Labor Arbiter dismissed Peckson's complaint, asserting his resignation was voluntary, supported by evidence of completed exit procedures and statements during his exit interview that indicated he was leaving for another job. This decision was affirmed by the National Labor Relations Commission (NLRC), which noted that Peckson's delayed filing of the complaint weakened his argument.
Court of Appeals Ruling
Upon appeal, the Court of Appeals found that Panasonic failed to demonstrate that Peckson's resignation was voluntary. It determined that the coercive actions of De Jesus, alongside the failure to appropriately place Peckson on "floating status," constituted constructive dismissal. Consequently, the CA awarded Peckson backwages, separation pay, and damages.
Issues on Review
The core issues presented revolve around whether Peckson's resignation was voluntary and whether Panasonic was liable for constructive dismissal.
Arguments of the Parties
Panasonic contended that the CA wrongly overturned previous findings of voluntariness based on Peckson's resignation letters, positive exit interview comments, and the time elapsed before filing the complaint. Peckson maintained that his resignation was involuntary, emphasizing the hostile work environment and misrepresentation of his reasons for leaving.
Court's Analysis
The Supreme Court granted the petition, finding substantial evidence supported Peckson's voluntary resignation. The Court highlighted that resigning employees must have presented evidence proving involuntariness when the employer asserts a resignation defense. The evaluation of Peckson's behavior— submitting gratitude-laden resignation letters, completing exit interviews, and signing quitclaims—indicated his voluntary departure.
Findings on Constructive Dismissal
The Court emphasized that constructive dismissal
...continue readingCase Syllabus (G.R. No. 206316)
Case Overview
- The case was brought before the Supreme Court through a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The Petition challenges the Decision of the Court of Appeals (CA) dated December 7, 2012, and its Resolution dated March 15, 2013.
- These decisions set aside earlier findings by the National Labor Relations Commission (NLRC) that ruled in favor of the petitioner, Panasonic Manufacturing Philippines Corporation (Panasonic), regarding respondent John Peckson's resignation.
Background Facts
- John Peckson was employed as a Sales Supervisor in the Battery Department of Panasonic.
- Peckson tendered his resignation in a letter dated September 16, 2003, effective October 30, 2003.
- He subsequently altered the effective date of his resignation to October 15, 2003, in a follow-up letter dated September 25, 2003.
- On April 11, 2005, Peckson filed a complaint for constructive dismissal, claiming he was forced to resign due to accusations from his manager, Jose De Jesus, regarding a falsified signature on an "Authority to Travel" form.
Complaint Details
- Peckson alleged that he was subject to unfair treatment by De Jesus, who disregarded a PNP Crime Laboratory report that cleared Peckson of any wrongdoing.
- Peckson claimed his employment status was unfairly affected, leading him to resign.
- He sought separation pay, non-payment of benefits, moral and exemplary damages, and attorney's fees.
Proceedings in the Labor Arbiter (LA) and NLRC
- The Labor Arbiter dismissed Peckson's complaint, asserting that his resignation was voluntary, supported by the submission of two resignation letters an