GR 160348; (December, 2004) (Digest)
G.R. No. 160348, December 17, 2004
Willi Hahn Enterprises and/or Willi Hahn, petitioner, vs. Lilia R. Maghuyop, respondent.
FACTS
Respondent Lilia Maghuyop was employed by petitioner Willi Hahn Enterprises, rising from a nanny to the store manager of its SM Cebu branch. In February 1998, an inventory revealed stock shortages and unremitted cash totaling P27,727.39 at her branch. In July 1998, before petitioner could terminate her services, respondent submitted a resignation letter dated July 22, 1998. Petitioner accepted the resignation and opted not to pursue charges for the shortages.
Subsequently, respondent filed a complaint for illegal dismissal, claiming the resignation was involuntary. She alleged that company agents ordered her to close the shop, typed the resignation letter themselves, and compelled her to sign it under duress before ejecting her from company housing. She sought backwages, separation pay, and other monetary claims.
ISSUE
Whether or not respondent Lilia Maghuyop was illegally dismissed, or whether her resignation was voluntary.
RULING
The Supreme Court ruled that respondent voluntarily resigned and was not illegally dismissed. The Court emphasized that resignation is a voluntary act, and the burden of proving it was involuntary due to coercion or vitiated consent lies with the employee making the allegation. Respondent failed to substantiate her claim of duress with clear and convincing evidence.
The Court found the resignation letter straightforward and candid. It noted that respondent, having attained a managerial position, could not credibly claim she did not understand the document’s consequences. Citing Callanta v. NLRC, the Court held that an employee’s voluntary signing of a resignation letter, especially when faced with an audit discrepancy, indicates a free and knowing act. Petitioner’s decision to forgo termination proceedings and potential criminal charges after the resignation was viewed as an act of compassion for a long-time employee, not proof of coercion. The factual findings of the Labor Arbiter and the NLRC, which found the resignation voluntary, were supported by substantial evidence and thus accorded finality. The Court of Appeals’ reversal was therefore set aside.