G.R. No. 140189 ; February 28, 2005
GREAT SOUTHERN MARITIME SERVICES CORPORATION, FERRY CASINOS LIMITED and PIONEER INSURANCE AND SURETY CORPORATION, petitioners, vs. JENNIFER ANNE B. ACUÑA, HAYDEE ANNE B. ACUÑA, MARITES T. CLARION, MARISSA C. ENRIQUEZ, GRACIELA M. TORRALBA and MARY PAMELA A. SANTIAGO, respondents.

FACTS

Respondents were deployed by petitioner Great Southern Maritime Services Corporation (GSMSC), a manning agency, to work as croupiers for petitioner Ferry Casinos Limited under six-month contracts. In July 1993, they were informed their services were no longer needed. Claiming their plane tickets were ready and they were subjected to harassment, they signed documents indicating they terminated their own employment and were subsequently repatriated. They filed a complaint for illegal dismissal.
Petitioners denied illegal dismissal, contending respondents voluntarily resigned en masse after exhibiting a lukewarm attitude and defiance. They presented resignation letters executed by the respondents. The POEA ruled in favor of the respondents, finding illegal dismissal and ordering payment of salaries for the unexpired contract portion. The NLRC reversed the POEA, dismissing the complaint and giving credence to the resignation letters and petitioners’ claim of mass resignation.

ISSUE

Whether the Court of Appeals erred in finding that respondents were illegally dismissed and in reinstating the POEA’s decision.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic centers on the burden of proof in dismissal cases and the validity of quitclaims. In termination disputes, the employer bears the burden to prove that the dismissal was for a just or authorized cause. Petitioners’ claim of voluntary resignation is a defense they must substantiate with clear, positive, and convincing evidence. The Court found petitioners failed to discharge this burden.
The purported resignation letters were effectively quitclaims obtained under circumstances negating voluntariness. The respondents, overseas workers with unequal bargaining power, signed the documents after being told their services were terminated and their plane tickets were ready, creating a coercive environment. A quitclaim executed by an employee pressured into signing receives scant consideration from the courts. The NLRC’s reliance on the fact that two respondents later found work abroad was irrelevant to the voluntariness of their resignation. Consequently, the dismissal, being unsupported by valid cause and due process, was illegal. The reinstatement of the POEA award for the unexpired salaries was proper.