G.R. No. 178453 April 16, 2009
Gloria Artiaga, Petitioner, vs. Siliman University and Siliman University Medical Center/Siliman University Medical Center Foundation, Inc., Respondents.

FACTS

Petitioner Gloria Artiaga was hired by respondent Siliman University Medical Center (SUMC) in June 1978. On September 13, 1998, while serving as Credit and Collection Officer, she submitted a letter which served as both an explanation and a resignation. In the letter, she admitted to committing errors and mistakes in the posting of ledger cards, expressed being crushed and troubled, asked for forgiveness and a chance to stand again, and stated, “please consider this letter a resignation letter.” Prior to this, an audit in September 1998 found irregularities under her control, including posting receipts for higher amounts than issued and using fictitious receipts, with an alleged misappropriation of &8369;300,000. On September 11, 1998, SUMC had issued a notice requiring her to explain within five days why no disciplinary action should be taken and placed her under preventive suspension. After her resignation, the operation of SUMC was transferred to Siliman University Medical Foundation, Inc. More than three years later, on November 6, 2001, Artiaga filed a complaint for constructive dismissal. She claimed she was forced to resign because she was suddenly instructed to endorse her responsibilities to a new employee, was given no new assignment, and was extremely humiliated. The Labor Arbiter dismissed her complaint. The NLRC reversed the Arbiter, finding constructive dismissal and ordering reinstatement with backwages. The Court of Appeals, on a petition for certiorari by respondents, reversed the NLRC and reinstated the Labor Arbiter’s decision.

ISSUE

Whether the Court of Appeals erred in reversing the NLRC’s finding that petitioner Gloria Artiaga was constructively dismissed.

RULING

The Supreme Court denied the petition and affirmed the Decision of the Court of Appeals. The Court held that the NLRC committed grave abuse of discretion by failing to consider the evidence adduced by the parties. Petitioner presented no evidence to substantiate her claim of constructive dismissal. In contrast, respondents presented documented evidence of petitioner’s irregular acts, the September 11, 1998 notice requiring her explanation, and her preventive suspension. Petitioner’s own September 13, 1998 letter-explanation cum resignation was self-explanatory and showed she received the notices and was responding to the audit findings. Her claim that the documents were fabricated was not persuasive, as her letter unquestionably referred to the matters subject of the notices. The broader interest of justice and public policy allowed the correction of the NLRC’s error via certiorari. Therefore, no constructive dismissal occurred.