The Supreme Court has ruled that employees who were misled into signing resignation letters under false pretenses are considered illegally dismissed. This decision emphasizes the importance of voluntariness in resignation and protects employees from deceptive employer practices. It ensures that employees are not tricked into giving up their jobs and legal rights through misrepresentation or coercion.

Tricked into Quitting: When Resignation Letters Hide Illegal Dismissal

This case revolves around several employees of Villaseran Maintenance Service Corp. who were assigned to Manila Central University Hospital (MCU). When MCU terminated its contract with Villaseran, the employees were assured of new assignments. However, they were asked to sign resignation letters and quitclaims, purportedly as a requirement for reassignment and to receive their final pay. These employees later claimed they were not given new assignments and that their resignations were not voluntary but a result of the employer’s deceit. This prompted them to file a case for illegal dismissal, leading to a legal battle that reached the Supreme Court. The central legal question is whether the employees voluntarily resigned or were illegally dismissed through the employer’s misrepresentation.

The Supreme Court emphasized that for a resignation to be considered valid, it must be a voluntary act by the employee, demonstrating a clear intention to relinquish their position. The act must be unconditional and accompanied by an intent to abandon the job. The burden of proving the voluntariness of resignation rests on the employer, especially when the employee denies the authenticity and due execution of resignation documents. As highlighted in Torreda v. Investment and Capital Corporation of the Philippines:

The act of the employee before and after the alleged resignation must be considered to determine whether in fact, he or she intended to relinquish such employment. If the employer introduces evidence purportedly executed by an employee as proof of voluntary resignation and the employee specifically denies the authenticity and due execution of said document, the employer is burdened to prove the due execution and genuineness of such document.

In this case, the employees argued that they signed the resignation letters and quitclaims under the false pretense that it was a requirement for their reassignment and final pay. The Supreme Court scrutinized the circumstances surrounding the signing of these documents. Resignation letters coupled with quitclaims are often viewed with disfavor, as they can be used to circumvent labor laws and deprive employees of their rights. To ensure the validity of such agreements, the Supreme Court referenced the guidelines set in Carolina’s Lace Shoppe v. Maquilan, which requires that:

1. A fixed amount as full and final compromise settlement;
2. The benefits of the employees if possible with the corresponding amounts, which the employees are giving up in consideration of the fixed compromise amount;
3. A statement that the employer has clearly explained to the employee in English, Filipino, or in the dialect known to the employees – that by signing the waiver or quitclaim, they are forfeiting or relinquishing their right to receive the benefits which are due them under the law; and
4. A statement that the employees signed and executed the document voluntarily, and had fully understood the contents of the document and that their consent was freely given without any threat, violence, duress, intimidation, or undue influence exerted on their person.

In this case, these requirements were not met. The amounts stated in the quitclaims corresponded to salary adjustments, which the employees were already entitled to, not a compromise for their resignation. There was no clear explanation of the implications of signing the documents, and no explicit statement confirming the employees’ voluntary consent. The handwritten resignation letters themselves were nearly identical, suggesting they were copied from a template, further casting doubt on their voluntariness. The Supreme Court noted the significance of the employees filing a complaint for illegal dismissal shortly after their alleged resignation. This action contradicts the idea of a voluntary resignation, as noted in ICT Marketing Services Inc. v. Sales:

[P]etitioner immediately filed a complaint for illegal dismissal. Resignation, it has been held, is inconsistent with the filing of a complaint. Thus, private respondent corporation’s mere assertion that petitioner voluntarily resigned without offering convincing evidence to prove it, is not sufficient to discharge the burden of proving such assertion. It is worthy to note that the fact of filing a resignation letter alone does not shift the burden of proof and it is still incumbent upon the employer to prove that the employee voluntarily resigned.

The Supreme Court found that the employees were indeed illegally dismissed, as their resignations were not voluntary but coerced through the employer’s deceptive practices. The fact that some employees were later absorbed by MCU’s new manpower agency did not absolve the employer of liability. As the Supreme Court explained in FVR Skills and Services Exponents, Inc. (Skillex) v. Seva, subsequent employment does not negate the fact of illegal dismissal if the initial separation was unlawful. In this case, the liability falls solely on Villaseran Maintenance Service Corp., as there was no clear evidence that Maria Antonia V. Mercado, the general manager, acted with malice or bad faith in her individual capacity. The Supreme Court affirmed the Labor Arbiter’s decision to award backwages, separation pay, pro-rata 13th-month pay, and attorney’s fees. These remedies are intended to compensate the employees for the injustice they suffered due to the illegal dismissal.

Backwages compensate the employees for the income they lost during the period they were unemployed due to the illegal dismissal. Separation pay provides a financial cushion to help them transition to new employment. The pro-rata 13th-month pay ensures they receive the benefits they earned up to the point of their dismissal. Attorney’s fees cover the costs they incurred in pursuing their legal claims. The Supreme Court further directed that the monetary awards should accrue interest from the finality of the decision until fully paid. This ensures that the employees are fully compensated for the delay in receiving their due benefits.

FAQs

What was the key issue in this case?	The key issue was whether the employees voluntarily resigned from their jobs or were illegally dismissed due to the employer’s misrepresentation.
What does it mean to resign voluntarily?	Voluntary resignation means an employee willingly and intentionally gives up their job, free from any coercion or deceit. It requires a clear intent to relinquish employment.
Who has the burden of proving if a resignation was voluntary?	The employer has the burden of proving that an employee’s resignation was voluntary, especially if the employee disputes the resignation’s validity.
What makes a resignation with a quitclaim invalid?	A resignation with a quitclaim can be invalid if it lacks clear statements of voluntary consent, fails to explain the rights being waived, or if the compensation is inadequate.
What did the court consider about the resignation letters in this case?	The court noted that the similarity in wording among the resignation letters suggested they were copied from a template, raising doubts about their voluntariness.
Why was the filing of an illegal dismissal complaint important?	Filing a complaint for illegal dismissal soon after resigning suggests the employee did not intend to voluntarily leave their job, which supports a claim of illegal dismissal.
Did it matter that some employees found new jobs?	No, the court ruled that subsequent employment does not negate the fact of illegal dismissal if the initial separation was unlawful.
What compensation were the employees entitled to?	The employees were entitled to backwages, separation pay, pro-rata 13th-month pay, and attorney’s fees to compensate them for the illegal dismissal.

This Supreme Court decision serves as a crucial reminder to employers to ensure that any resignation is genuinely voluntary and free from coercion or misrepresentation. It underscores the importance of fair labor practices and protects the rights of employees who may be vulnerable to deceptive tactics. By invalidating the resignations and awarding appropriate compensation, the court reaffirmed the principles of security of tenure and justice in employment relations.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: RAYMOND D. JACOB vs. VILLASERAN MAINTENANCE SERVICE CORP., G.R. No. 243951, January 20, 2021