Case Summary (G.R. No. 189358)
Factual Background and Employment History
Rodriguez was transferred from restaurant work to administrative and finance duties after the original business closed. Over time, she handled personnel and administrative matters for the multiple companies controlled by the Javier Spouses without additional compensation and performed various household tasks for the spouses as well. She worked lengthy hours, was on call even on Sundays and holidays, received wage deductions for absences, and was allegedly denied service incentive leave pay.
Incident Leading to Resignation and Alleged Constructive Dismissal
Rodriguez complained of unreasonable and degrading treatment by Estelita Javier, including a specific confrontation on September 22, 2009, when Estelita berated her for opening the office late and stated, "If you no longer want to do your work, we can manage without you." Rodriguez then stopped reporting to work, submitted a letter expressing grievances, and claimed she was constructively dismissed due to a hostile work atmosphere. Respondents allegedly did not accept her resignation initially but accepted it in writing on October 6, 2009.
Respondents' Position and Allegations Against Petitioner
The Javier Spouses stated that Rodriguez was a senior, trusted employee with significant responsibilities, including custody of company files, bank account signatory authority, and handling financial transactions. They claimed that Rodriguez was emotionally sensitive, prone to “tampo” (sulking), and had previously tendered and withdrawn resignations. They alleged Rodriguez had unauthorized absences starting in September 2009 and failed to complete clearances. Moreover, they discovered missing company checkbooks, unliquidated cash advances exceeding P500,000, and two checks worth P936,000 deposited into her personal account, leading to loss of trust and the initiation of an investigation.
Labor Arbiter’s and National Labor Relations Commission’s (NLRC) Decisions
Labor Arbiter Antonio R. Macam dismissed Rodriguez’s complaint for lack of merit, ruling that her resignation was voluntary and was not due to a hostile work environment. The Arbiter ordered payment of proportionate 13th-month pay for 2009 only.
The NLRC initially reversed this, ruling in favor of Rodriguez and awarding back wages, separation pay, 13th-month pay differentials, moral and exemplary damages, and attorney’s fees. However, upon motion for reconsideration by the respondents, the NLRC reinstated the Labor Arbiter's decision, recognizing Rodriguez's resignation as voluntary.
Court of Appeals’ Decision
The Court of Appeals (CA) affirmed the NLRC’s ruling that there was no illegal dismissal or constructive dismissal. It held that Rodriguez voluntarily resigned and that while the respondents were to pay her service incentive leave pay and 13th-month pay for 2006 to 2009 plus attorney’s fees, there was no basis for damages. The CA stressed that isolated harsh words by the employer do not create from themselves a hostile work environment warranting constructive dismissal and that the totality of circumstances negated petitioner’s claim.
Issues on Appeal to the Supreme Court
The issues were whether Rodriguez was constructively dismissed and, if not, whether she was entitled to full service incentive leave pay for her entire 25-year employment and to damages for the alleged inhumane treatment.
Legal Standard on Constructive Dismissal
Constructive dismissal occurs when the employer’s acts of clear discrimination, insensitivity, or disdain become so unbearable as to leave the employee no reasonable choice but to resign. The test is whether a reasonable person in the employee’s position would be compelled to resign. Occasional misunderstandings or reasonable reprimands do not constitute constructive dismissal.
Supreme Court’s Findings on Constructive Dismissal
The Supreme Court found no palpable error in the CA and labor tribunals’ factual findings that the resignation was voluntary and not induced by a hostile working environment. Affidavits indicated respondents’ trust and confidence in Rodriguez, who enjoyed close working relations with the Javier Spouses and held significant responsibilities. Rodriguez’s letters of resignation expressed gratitude, inconsistent with forced resignation. The isolated harsh words by Estelita Javier were held to be a spontaneous outburst due to petitioner’s failure to liquidate large cash advances, and not a maneuver to force resignation.
Supreme Court’s Findings on Monetary Claims
Since there was no illegal dismissal, moral and exemplary damages were not warranted. However, on the issue of service incentive leave pay, the Court corrected the CA’s limited award to three years. It clarified that, under Article 291 of the Labor Code and jurisprudence, service incentive leave pay is a peculiar benefit that accrues yearly and may be accumulated and commuted to monetary value upon separation. The cause of action to claim unpaid service incentive leave pay arises only upon employer’s refusal to pay upon separation. Therefore, c
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Case Syllabus (G.R. No. 189358)
Case Background and Procedural Posture
- Petitioner Lourdes C. Rodriguez filed a Complaint on October 7, 2009, alleging constructive illegal dismissal, non-payment of service incentive leave pay and 13th month pay, and claims for moral and exemplary damages plus attorney's fees against respondents Park N Ride Inc., Vicest (Phils) Inc., Grand Leisure Corp., and the spouses Vicente and Estelita B. Javier (Javier Spouses).
- Rodriguez’s employment began on January 30, 1984, as a Restaurant Supervisor at Vicest Phils.
- After the closure of the restaurant business, Rodriguez was transferred to office work as Administrative and Finance Assistant.
- Rodriguez handled multiple roles including personnel and administrative matters of several companies owned by the Javier Spouses, and also household tasks, without additional compensation.
- Rodriguez worked long hours, was on call including Sundays and holidays, subject to wage deductions for absences, and was not paid service incentive leave pay.
- There were repeated tensions culminating in Rodriguez submitting resignation letters effective May 25, 2008, and April 25, 2009, both containing words of gratitude.
- Respondents initially did not accept the resignation but later acknowledged it; allegations of unfair treatment and hostility were raised by Rodriguez.
- Labor Arbiter Antonio R. Macam dismissed Rodriguez’s complaint due to findings of voluntary resignation.
- The National Labor Relations Commission (NLRC) initially ruled in favor of Rodriguez finding illegal dismissal but later reversed on motion for reconsideration.
- The Court of Appeals upheld the findings of the Labor Arbiter and NLRC in its December 15, 2015 Decision, ruling no illegal dismissal but awarding service incentive leave pay and 13th month pay for 2006 to 2009 plus attorney’s fees.
- Petitioner’s motion for reconsideration was denied, prompting this Petition for Review under Rule 45.
Facts on Employment, Duties, and Working Conditions
- Rodriguez’s employment trajectory involved multiple roles across the business ventures of the Javiers: fast food, construction, parking terminal, finance, and administration.
- She was entrusted with sensitive tasks including custody of company and personal documents, handling banking transactions, payrolls, and household duties.
- Worked daily from 8:00 a.m. to 7:00 p.m. six days a week with Sunday on-call duty and holiday work.
- Wage deductions applied for absence days; service incentive leave pay was not provided.
- Claimed environment became unbearable due to Estelita Javier’s unreasonable and humiliating behavior in front of coworkers.
- An incident on September 22, 2009, wherein Estelita reprimanded Rodriguez for opening the office late and made a remark about the company managing without her if she ceased working, triggered non-reporting the next day by Rodriguez.
- Rodriguez alleges constructive dismissal based on hostile work environment and expressions by the employer.
Respondents’ Position and Allegations Against Petitioner
- Javier Spouses clarified that Rodriguez’s resignation was voluntary and that she was emotionally sensitive and prone to “tampo” leading to absences after reprimands.
- Highlighted Rodriguez’s high degree of trust and seniority in handling business and personal affairs.
- Disclosed significant irregularities discovere