GR 184397; (September, 2015) (Digest)
G.R. No. 184397 September 9, 2015
ROSALINDA G. PAREDES, Petitioner, vs. FEED THE CHILDREN PHILIPPINES, INC. and/or DR. VIRGINIA LAO, HERCULES PARADIANG and BENJAMIN ESCOBIA, Respondents.
FACTS
Petitioner Rosalinda G. Paredes was the National Director of respondent Feed the Children Philippines, Inc. (FTCP), a non-government organization. Her duties included project management, fund accessing, financial management, and administration. She signed all FTCP checks and approved all requisitions and disbursements. On August 12, 2005, 42 FTCP employees submitted a petition to the Board of Trustees complaining about petitioner’s management practices. The Board discussed the issue in a meeting on August 28, 2005, initially excluding petitioner for three hours. The Board decided to form a Supervisory Team and hire an independent management and financial auditor. Petitioner, through her lawyers, questioned the scope and legality of the audit and demanded that the manual of operations be followed. On October 24, 2005, auditors arrived at the FTCP office, but petitioner, who was out of town, refused to accommodate them without first receiving the requested information about the audit. The Board resolved to suspend petitioner for her refusal to submit to the audit. Before the suspension could be implemented, petitioner submitted a resignation letter dated October 28, 2005, stating she could only serve until December 31, 2005, as it was no longer tenable to work with the Board due to differences. The Board accepted her resignation but moved the effectivity to November 30, 2005, paying her November salary while not requiring her to report for work. Petitioner then informed management and foreign funders she was no longer connected with FTCP, moved her belongings, and took FTCP documents. On November 2, 2005, she filed a complaint for illegal dismissal, claiming constructive dismissal. The Labor Arbiter dismissed her complaint, finding she voluntarily resigned and ordering her to pay various sums to FTCP and the individual respondents. The NLRC reversed the Labor Arbiter, finding constructive dismissal and ordering FTCP to pay her salaries for the unexpired portion of her contract and damages. The Court of Appeals then annulled the NLRC decision, reinstating the Labor Arbiter’s finding of voluntary resignation and ordering petitioner to pay certain amounts to FTCP.
ISSUE
Whether the Court of Appeals erred in ruling that petitioner voluntarily resigned from her employment and was not constructively dismissed.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals decision. The Court held that petitioner voluntarily resigned and was not constructively dismissed. The resignation letter was couched in clear and unequivocal terms, stating her decision to leave due to irreconcilable differences with the Board. Her subsequent acts—immediately informing others of her severance from FTCP, vacating her office, and taking FTCP documents—confirmed her intention to resign. The Court found no evidence that the employer forced her resignation or committed acts of discrimination, insensibility, or humiliation that would make continued employment intolerable. The Board’s actions (forming a Supervisory Team, ordering an audit) were legitimate management prerogatives to address staff complaints and ensure organizational integrity, not acts of harassment. The acceptance of her resignation by the Board, with the grant of a one-month salary without requiring work, was a gracious act, not an indication of forced resignation. Therefore, no constructive dismissal occurred. The Court also modified the monetary awards, deleting the awards for moral and exemplary damages and attorney’s fees against petitioner, as the Labor Arbiter’s decision on these matters had become final due to FTCP’s failure to appeal them. Petitioner was ordered to pay FTCP the amounts for her unpaid loans and unauthorized Provident Fund withdrawals as affirmed by the Court of Appeals.
