G.R. No. 170266. September 12, 2008
ENGRACIO A. GUERZON, JR., LILIAN E. CRUZ, and JOSEFINA O. BAUYON, Petitioners, v. PASIG INDUSTRIES, INC., MASAHIRO FUKADA, and YOSHIKITSU FUJITA, Respondents.

FACTS

Petitioners were long-time employees of respondent Pasig Industries, Inc. (PII). In 1995, PII informed them of a decision to close its Makati office and transfer operations to Bataan. They were offered a special separation package (SSP) equivalent to one month’s basic salary per year of service if they opted to resign. Petitioners negotiated for a recomputation based on gross pay (basic salary plus allowances), to which PII agreed. They subsequently received and accepted the recomputed SSP payments on September 25, 1995.
Two days after receiving payment, petitioners filed a complaint for illegal dismissal, seeking additional separation pay, retirement benefits, and other monetary claims. The Labor Arbiter ruled in their favor, finding illegal dismissal. The NLRC reversed, holding that petitioners voluntarily accepted the SSP after successful negotiations. The Court of Appeals affirmed the NLRC’s decision.

ISSUE

Whether petitioners were illegally dismissed, entitling them to further relief, or whether their acceptance of the separation package constituted a voluntary resignation.

RULING

The Supreme Court denied the petition, upholding the voluntary nature of petitioners’ separation. The legal logic centered on the principle of voluntary resignation and estoppel. Petitioners, being responsible employees with substantial tenure and professional standing, were presumed to understand the consequences of their actions. Their act of negotiating for and successfully obtaining an improved separation package—based on gross pay rather than basic salary—demonstrated a clear, deliberate choice to avail themselves of the offered benefits. By accepting the computed and paid amounts, they effectively voluntarily resigned from employment.
Consequently, the question of whether PII’s operational streamlining constituted an authorized cause for termination under Article 283 of the Labor Code became immaterial. Their voluntary act of resigning for a valuable consideration precluded a finding of illegal dismissal. The Court emphasized that employees who voluntarily agree to terminate their employment, especially after bargaining for better terms, cannot later claim they were illegally dismissed. The acceptance of the separation pay operated as a waiver of any further claims arising from the termination of employment.