Case Summary (G.R. No. 154503)
Background of the Case
- Amalia P. Kawada began her employment with Uniwide Sales Warehouse Club in 1981 and rose to the position of Full Assistant Store Manager by 1995.
- Her responsibilities included managing various departments and ensuring compliance with company policies.
- In 1998, reports of unsatisfactory performance were received regarding Kawada's management, prompting Uniwide to issue several memoranda addressing various allegations against her.
Allegations and Responses
- The initial memorandum on March 15, 1998, outlined issues such as the commingling of good and damaged items and failure to submit inventory reports.
- Kawada responded to these allegations on March 23, 1998, but her answers were deemed unsatisfactory by her superior, Vivian Apduhan.
- Subsequent memoranda detailed further allegations, including allowing unauthorized access to restricted areas and falsifying records.
Medical Issues and Confrontation
- Kawada sought medical attention for hypertension and was advised to take sick leave.
- A medical certificate issued by Dr. Zambrano contained an error regarding her surname, leading to a confrontation with Apduhan.
- Kawada claimed that Apduhan's shouting during this confrontation exacerbated her medical condition, resulting in her collapse.
Legal Proceedings Initiated by Kawada
- Following the incident, Kawada reported the confrontation to the police and sought legal counsel.
- On August 3, 1998, she filed a case for illegal dismissal against Uniwide and Apduhan.
- Apduhan issued a memorandum on August 2, 1998, scheduling a hearing for August 12, 1998, which Kawada did not attend.
Labor Arbiter's Decision
- The Labor Arbiter dismissed Kawada's complaint for lack of merit on March 9, 1999.
- Kawada appealed this decision to the National Labor Relations Commission (NLRC), which ruled in her favor, declaring her constructively dismissed.
NLRC's Findings
- The NLRC found that Kawada was subjected to oppressive treatment and that the successive memoranda constituted harassment.
- It ruled that Kawada was not afforded due process, as the investigation occurred after her alleged constructive dismissal.
Court of Appeals' Ruling
- The Court of Appeals affirmed the NLRC's decision, leading to the current petition for review by Uniwide and Apduhan.
- The primary issue was whether the Court of Appeals erred in sustaining the NLRC's finding of constructive dismissal.
Supreme Court's Review of the Case
- The Supreme Court emphasized its limited jurisdiction to review errors of law, not fact, but noted the conflicting factual findings between the Labor Arbiter and the NLRC.
- The Court found insufficient evidence to support the conclusion that Kawada was constructively dismissed.
Definition and Criteria of Constructive Dismissal
- Constructive dismissal is defined as a situation where continued employment becomes impossible or unreasonable due to employer actions.
- The Court reiterated that the test for constructive dismissal is whether a reasonable person would feel compelled to resign under the circumstances.
Analysis of Allegations of Harassment
- The Court found Kawada's claims of harassment to be unsubstantiated and noted that the memoranda were part of management's prerogative to discipline employees.
- The July 31, 1998 incident was deemed an isolated event and insufficient to establish a pattern of harassment.
Findings on Abandonment of Work
- The Court ruled that Kawada&...continue reading