G.R. No. 177114 ; April 13, 2010
MANOLO A. PEÑAFLOR, Petitioner, vs. OUTDOOR CLOTHING MANUFACTURING CORPORATION, NATHANIEL T. SYFU, President, MEDYLENE M. DEMOGENA, Finance Manager, and PAUL LEE, Chairman, Respondents.

FACTS

Petitioner Manolo Peñaflor was hired as a probationary HRD Manager by respondent Outdoor Clothing Manufacturing Corporation on September 2, 1999. On March 13, 2000, he learned that the company president, Nathaniel Syfu, had appointed Edwin Buenaobra as the concurrent HRD and Accounting Manager. Peñaflor considered this appointment, coupled with alleged discriminatory treatment, as the final act forcing his hand. He subsequently filed an irrevocable resignation effective March 15, 2000, and then lodged an illegal dismissal complaint, claiming constructive dismissal. The Labor Arbiter ruled in his favor, but the NLRC reversed this decision, a ruling later affirmed by the Court of Appeals.

ISSUE

The core issue was whether Peñaflor’s resignation was voluntary or a forced act constituting constructive dismissal. A pivotal factual question was the sequence of events: whether his resignation was submitted before or after the appointment of his replacement.

RULING

The Supreme Court granted the petition, finding constructive dismissal. The legal logic centered on the credibility of evidence regarding the timing of the resignation. Outdoor Clothing presented memoranda dated March 1, 3, and 10, 2000, to prove the appointment preceded the resignation, claiming Peñaflor resigned on March 1. However, the Court found these documents highly suspect. They were only presented on appeal to the NLRC, not before the Labor Arbiter, and their belated submission lacked justification. Their authenticity was doubtful, as Peñaflor was never informed of them, and there were no indications the intended recipients actually received the March 1 and 3 memoranda.
Furthermore, the surrounding circumstances made Outdoor Clothing’s timeline implausible. It was illogical for Peñaflor to resign voluntarily on March 1, the very day he would have attained regular employee status, thereby forfeiting security of tenure and potential separation benefits during a company downsizing. The Court concluded Peñaflor resigned on March 15 in response to the unacceptable appointment of Buenaobra to his still-occupied position. This act of effectively replacing him rendered his continued employment intolerable, forcing his resignation. Applying the principle that doubts in evidence are resolved in favor of labor, the resignation was deemed involuntary, constituting constructive dismissal.
On the Motion for Reconsideration, the Court modified its prior ruling on liability. While it upheld the finding of constructive dismissal, it absolved the individual corporate officers (Syfu, Demogena, and Lee) from solidary liability. The Court reiterated that corporate officers are not personally liable for corporate obligations arising from illegal dismissal unless malice or bad faith is proven, which was not sufficiently established here. Only the corporate entity, Outdoor Clothing, was held liable for the awarded backwages, separation pay, illegally deducted salary, proportionate 13th month pay, attorney’s fees, moral and exemplary damages, and costs.