GR 154376; (September, 2005) (Digest)
G.R. No. 154376. September 30, 2005.
ROBERTO T. DOMONDON, Petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, VAN MELLE PHILS., INC. and NIELS H.B. HAVE, Respondents.
FACTS
Petitioner Roberto Domondon was hired as Materials Manager by respondent Van Melle Phils., Inc. (VMPI). He alleged that after a change in company presidency, the new president, respondent Niels Have, pressured him to resign as part of a management reorganization. Domondon claimed that during a meeting on June 10, 1998, Have presented a veiled threat, stating a “dignified resignation would be infinitely better than being fired for a fabricated lawful cause,” and offered immediate financial assistance contingent on his immediate resignation. Feeling coerced, Domondon signed a pre-prepared resignation letter. He subsequently filed a complaint for illegal dismissal, asserting his resignation was involuntary.
Respondents VMPI and Have denied the allegations of coercion. They contended that Domondon voluntarily resigned to pursue a management consultancy business, as stated in his resignation letter. They presented evidence that Domondon had requested and received a “soft landing” financial package, including a negotiated arrangement to purchase his company car using the provided financial assistance. They argued that his actions following his resignation, including negotiating benefits and transferring the car’s ownership to himself, were inconsistent with a claim of forced resignation.
ISSUE
Whether or not petitioner Roberto Domondon was illegally dismissed, rendering his resignation involuntary.
RULING
The Supreme Court denied the petition and upheld the findings of voluntary resignation. The Court emphasized that in termination cases, the burden of proof rests upon the employee to substantiate the claim of illegal dismissal. For a resignation to be considered involuntary due to coercion, the compulsion must be shown to be real, serious, and overpowering, such that it vitiates the employee’s free will. Mere dissatisfaction with work conditions or the prospect of an unpleasant alternative does not constitute coercion.
The Court found that Domondon failed to discharge this burden of proof. His resignation letter was clear, unambiguous, and stated a personal reason for leaving. His subsequent acts—specifically, requesting and accepting a substantial financial package, negotiating for the transfer of his company car, and effecting the registration of the car in his name—were deemed acts of a rational mind exercising free choice, utterly incompatible with his claim of being forced out. These actions, performed after the alleged coercive incident, convincingly demonstrated that his resignation was a deliberate and voluntary act. The consistent factual findings of the Labor Arbiter, the NLRC, and the Court of Appeals, which found no evidence of coercion sufficient to nullify his consent, were accorded finality.
