G.R. No. 192488 . April 19, 2016.
BLUE EAGLE MANAGEMENT, INC., MA. AMELIA S. BONOAN, AND CARMELITA S. DELA RAMA, PETITIONERS, VS. JOCELYN L. NAVAL, RESPONDENT.

FACTS

Petitioner Blue Eagle Management, Inc. (BEMI) operated the Moro Lorenzo Sports Center. Due to substantial financial losses, BEMI’s management decided to retrench employees to reduce operational costs. Respondent Jocelyn L. Naval, a maintenance staff member hired in 2005, was identified for retrenchment due to her short tenure. Before formal retrenchment proceedings, BEMI’s HR Manager, petitioner Carmelita Dela Rama, offered Naval and four other employees the option to voluntarily resign. This option included receiving their full salary for February 2006, pro-rated 13th-month pay, and financial assistance equivalent to one month’s salary per year of service, without requiring them to report for work thereafter.
Naval accepted the offer. On February 20, 2006, she executed a handwritten resignation letter in Dela Rama’s presence, which was approved the same day. She was instructed to return on February 28 to complete exit procedures and receive her monetary benefits. However, Naval failed to appear on that date. Instead, she later filed a complaint for illegal dismissal, claiming her resignation was involuntary and coerced due to the impending retrenchment.

ISSUE

Whether or not respondent Jocelyn L. Naval was illegally dismissed.

RULING

No, Naval was not illegally dismissed. The Supreme Court upheld the validity of her voluntary resignation. The Court emphasized that resignation is a voluntary act; the employee’s freedom of choice is the crucial element, not the absence of pressure. The factual circumstances demonstrated Naval’s voluntary decision: she was presented with a choice between retrenchment and resignation; she was given time to deliberate; she returned hours later to submit a handwritten resignation; and she did not immediately protest or revoke her resignation. The offer of a more attractive financial package for resignation than what was legally due for retrenchment did not constitute coercion or vitiate consent. It was a legitimate management prerogative to offer an alternative to the harshness of retrenchment.
The Court found no evidence of duress or force. Naval’s subsequent claim of coercion was belied by her own actions. Her failure to appear on the designated date to claim her benefits, while the four other employees who similarly resigned did so and executed release waivers, further undermined her claim. Therefore, her separation from employment was a product of her voluntary resignation, not an illegal dismissal. The employer complied with the law by accepting the resignation and offering the attendant benefits. The petition was granted, reversing the Court of Appeals and reinstating the NLRC decision which had dismissed Naval’s complaint.