Case Summary (G.R. No. 250205)
Antecedents
Vergara was employed by ANZ as a Risk Manager, having joined the company on November 30, 2010. He tendered his resignation effective September 6, 2016, but attempted to withdraw this resignation on September 5, 2016, after learning of the impending restructuring that would affect his role. Despite sending an email to the appropriate supervisor, he was informed on September 6 that his resignation had already been accepted. Consequently, Vergara filed a complaint for illegal dismissal and related monetary claims against the respondent, arguing that his resignation was validly retracted prior to official acceptance.
Procedural Background
The Labor Arbiter dismissed Vergara's complaint for lack of merit, ruling that his resignation was validly accepted before he retracted it. The decision, however, awarded Vergara his proportionate 13th month pay. Both parties subsequently appealed to the National Labor Relations Commission (NLRC), which modified the Labor Arbiter's ruling, asserting that Vergara had validly withdrawn his resignation prior to its acceptance, thereby finding no illegal dismissal but ordering the payment of separation pay and 13th month pay.
Court of Appeals Ruling
Dissatisfied with the NLRC's resolution, the respondent filed a petition for certiorari before the Court of Appeals. The CA reversed the NLRC's decision, reinstating the Labor Arbiter's ruling. It held that substantial evidence established that Vergara's resignation was accepted prior to the attempted retraction.
Legal Issue
The principal legal issue before the Supreme Court is whether the Court of Appeals erred in determining that Vergara's resignation was accepted by ANZ before he withdrew it.
Court’s Ruling
The Supreme Court found in favor of Vergara, ruling that the Labor Arbiter had erred in concluding that the resignation was effectively accepted. The Court noted that the process of resignation acceptance required a formal acknowledgment, which was not present in this case. It emphasized that the triggering of the Employee Leaving Advice (ELA) by Vergara's line manager did not constitute a proper acceptance of resignation under the law.
Findings on Resignation Acceptance
The Court underscored that acceptance of resignation is a requisite for its validity. Reviewing the evidence, the Court agreed with the NLRC's assessment that Vergara's resignation was ineffectual due to t
...continue readingCase Syllabus (G.R. No. 250205)
Background of the Case
- The case arises from a Petition for Review on Certiorari filed by John Roger Niao S. Vergara (petitioner) against ANZ Global Services and Operations Manila, Inc. (respondent) to annul the Decision dated January 17, 2019, and the Resolution dated October 24, 2019, of the Court of Appeals (CA) in CA-G.R. SP No. 151874.
- Petitioner was employed by the respondent as a Risk Manager from November 30, 2010, until his resignation on August 5, 2016.
- Petitioner intended to resign, stating September 6, 2016, as his last working day. However, he later sought to withdraw his resignation on September 5, 2016, which led to a dispute over whether his resignation was effectively accepted.
Antecedents Leading to the Dispute
- On August 5, 2016, petitioner submitted a resignation letter to his Line Manager, Kristine Gorospe.
- On August 15, 2016, petitioner learned of an impending company restructuring that would include severance packages for displaced employees.
- Petitioner checked on the status of his Resignation Acceptance Form (RAF) on September 1, 2016, and found it unsigned.
- After realizing the impact of the restructuring, petitioner attempted to withdraw his resignation via email on September 5, 2016.
- On September 6, 2016, he received notification from Human Resources that his resignation had been accepted and could not be retracted