Title
Reyes vs. National Labor Relations Commission
Case
G.R. No. 78997
Decision Date
Aug 31, 1989
Teacher forced to resign due to health issues; promised re-employment denied. Court ruled involuntary resignation, illegal dismissal, ordered reinstatement, backwages, or separation pay.
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Case Summary (G.R. No. 78997)

Involuntariness of Resignation

  • The National Labor Relations Commission (NLRC) exhibited grave abuse of discretion by ignoring evidence indicating that the petitioner’s resignation was involuntary.
  • The resignation was coerced by the employer, who promised the petitioner priority for re-employment and immediate payment of her two months' vacation pay, which she urgently needed due to illness.
  • The petitioner’s resignation letter explicitly stated her conditions for resigning, including the expectation of being prioritized for re-employment and the urgent need for her vacation pay.

Right to Indefinite Leave of Absence

  • The school unlawfully denied the petitioner’s application for an indefinite leave of absence due to illness resulting from childbirth.
  • Article 133(b) of the Labor Code mandates that maternity leave should be extended without pay for illnesses arising from pregnancy or childbirth, unless the employee has unused leave credits.
  • The school’s actions to force the petitioner to resign instead of granting her leave were unjustifiable and contrary to labor laws.

Unauthorized Signing of Resignation Letter

  • The school attempted to absolve itself from its promise to re-hire the petitioner by having her husband sign an unconditional resignation letter on her behalf.
  • This letter is not binding on the petitioner as there is no evidence of her authorization for her husband to sign it, nor did it waive her rights to re-employment or separation pay.
  • The lack of authorization undermines the validity of the resignation and the school’s attempt to escape its obligations.

Illegal Dismissal and Entitlement to Backwages

  • The school’s refusal to re-employ the petitioner, despite its prior promise, constituted illegal dismissal.
  • The petitioner is entitled to reinstatement along with three years of backwages, as established in relevant case law.
  • The NLRC’s dismissal of the petitioner’s claims was erroneous, as it failed to recognize the nature of her resignation and the school’s obligations.

Payment of Separation Pay

  • If rein...continue reading

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