GR 121486; (November, 1998) (Digest)
G.R. No. 121486 November 16, 1998
ANTONIO HABANA, petitioner, vs. THE NATIONAL LABOR RELATIONS COMMISSION, HOTEL NIKKO MANILA GARDEN, MASAKASU TSURUOKA, MASAO YOKOO, and TAMIYASU OKAWA, respondents.
FACTS
Petitioner Antonio Habana was employed as Rooms Division Director by Hotel Nikko Manila Garden. During his tenure, management expressed concern over conflicts and disunity between Habana and his managerial staff, particularly Senior Rooms Manager Dolores Samson. Memoranda were issued urging Habana to resolve these issues and improve teamwork. In April 1990, following these difficulties, Habana negotiated with the hotel’s Human Resources Manager, Lourdes Aragon, for his separation from employment. They agreed on a separation pay of P120,000.00. Habana subsequently submitted a resignation letter, received the payment, and executed a quitclaim and release.
ISSUE
The core issue is whether petitioner Antonio Habana was illegally dismissed or if he voluntarily resigned, thereby rendering the quitclaim and release valid.
RULING
The Supreme Court ruled that Habana was not illegally dismissed but voluntarily resigned. The legal logic rests on the principle that resignation is a voluntary act, and the burden of proving it was involuntary due to coercion or vitiated consent lies with the employee. The Court found Habana failed to substantiate his claim of forced resignation. The evidence showed he initiated negotiations for separation pay, actively participated in determining the amount, and willingly submitted his resignation letter. His acceptance of the substantial separation pay and execution of a quitclaim, without immediate protest, strongly indicated voluntariness. The Court emphasized that a quitclaim executed by an employee, who has received benefits far beyond legal requirements, is a valid compromise agreement binding on the parties. Allowing repudiation after receiving such consideration would constitute unjust enrichment. His subsequent letter of protest, sent only after receiving the payment, was deemed an act of bad faith. Consequently, his claims for illegal dismissal and damages were denied.