G.R. No. 174644 ; August 10, 2007
Globe Telecom and Ma. Caridad D. Gonzales, petitioners, vs. Jenette Marie B. Crisologo, respondent.

FACTS

Respondent Jenette Marie B. Crisologo, a lawyer and manager at Globe Telecom, was rushed to the hospital on April 5, 2002, due to a pregnancy-related condition. After a week’s absence, she reported back to work on April 12, 2002, and immediately tendered her resignation letter, citing her doctor’s advice to rest for the duration of her pregnancy. She requested to exhaust her unused leaves until the resignation’s effective date of May 30, 2002, which Globe accepted. On April 30, during a conversation with her supervisor, petitioner Ma. Caridad Gonzales, respondent was casually informed of a circulating email alleging she solicited money from a company supplier. Respondent demanded a copy and a chance to confront the source, but Gonzales declined, stating the matter was closed.
Subsequently, respondent sent letters alleging ill-treatment and insisting her resignation was solely due to the damaging rumor. She demanded a certification clearing her name. Globe responded by reminding her of standard clearance procedures and requesting she settle her outstanding accountabilities first. Believing her demands would not be met, respondent filed a complaint for illegal dismissal on July 3, 2002, claiming she was forced to resign based on an unsubstantiated rumor without due process.

ISSUE

Whether or not respondent Jenette Marie B. Crisologo was illegally dismissed, or whether she voluntarily resigned from her employment.

RULING

The Supreme Court ruled that respondent voluntarily resigned and was not illegally dismissed. The Court departed from the factual findings of the Court of Appeals, which had nullified the NLRC’s decision, noting an exception to the general rule of finality of factual findings in labor cases when the CA’s conclusions conflict with those of the NLRC and labor arbiter. The legal logic centered on the evidence of resignation and the absence of vitiated consent.
The Court found respondent’s clear and unequivocal resignation letter, submitted two weeks before the rumor was even mentioned to her, as the most compelling proof of voluntary resignation. As an experienced lawyer in a high-ranking position, her claim of being forced to resign by a mere rumor discussed after her resignation was tendered defied logic and human experience. The Court emphasized that resignation is a voluntary act, and the burden to prove it was involuntary due to coercion or duress lies with the employee. Respondent failed to substantiate her claim of vitiated consent with clear and positive evidence. Her subsequent letters, which attempted to recast her resignation as forced, were deemed mere afterthoughts. Therefore, no illegal dismissal occurred.