G.R. No. 200898 , June 15, 2015.
BROWN MADONNA PRESS INC., THADDEUS ANTHONY A. CABANGON, FORTUNE LIFE INSURANCE COMPANY (now Fortune General Insurance Corporation) and/or ANTONIO CABANGON CHUA, Petitioners, vs. MARIA ROSARIO M. CASAS, Respondent.

FACTS

Respondent Maria Rosario M. Casas was hired on May 1, 1984, at Fortune General Insurance and later transferred to petitioner Brown Madonna Press, Inc. (BMPI) on December 1, 2003, as Vice President for Finance and Administration. On January 5, 2007, Casas met with BMPI President Thaddeus Anthony Cabangon and a human resource officer. Casas claims she was told not to report for work anymore starting January 8, 2007, upon instructions of Chairman Emeritus Antonio Cabangon Chua, with a promise of separation pay. BMPI asserts that Casas requested a “graceful exit” during the meeting to avoid an administrative investigation regarding complaints against her and to jumpstart a new career. Casas did not report for work on January 8, 2007. BMPI processed a “Clearance and Quitclaim” document stating Casas would “cease to be connected with the company at the close of office hours on January 16, 2007.” On May 17, 2007, Casas sent a letter seeking reconsideration of her termination, which went unanswered. On July 20, 2007, Casas filed a complaint for illegal dismissal, separation pay, backwages, retirement benefits, and attorney’s fees. The Labor Arbiter dismissed the complaint, finding Casas abandoned her work and was not dismissed. The National Labor Relations Commission (NLRC) reversed the Labor Arbiter, finding Casas was illegally dismissed without just cause and due process, as evidenced by the “Clearance and Quitclaim” document and BMPI’s failure to act on her reconsideration letter. The Court of Appeals affirmed the NLRC ruling.

ISSUE

Whether the Court of Appeals erred in finding no grave abuse of discretion in the NLRC’s ruling that Casas had been illegally dismissed.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals decision. The Court held that the CA did not err in finding that the NLRC did not commit grave abuse of discretion. The core issue of whether Casas voluntarily resigned or was dismissed is a question of fact. In a Rule 45 petition reviewing a CA decision on a Rule 65 petition concerning an NLRC ruling, the Court’s role is limited to determining whether the CA correctly found that the NLRC did not commit grave abuse of discretion. The NLRC’s factual finding that Casas was dismissed was supported by evidence, specifically the “Clearance and Quitclaim” document unilaterally prepared by BMPI indicating the severance of employment, and BMPI’s failure to respond to Casas’s reconsideration letter. BMPI failed to prove Casas voluntarily resigned, as it presented no resignation letter. The dismissal was without just cause, as the alleged infractions were never investigated, and without due process, as BMPI did not comply with the twin-notice requirement. Therefore, Casas was illegally dismissed and entitled to backwages, separation pay, and attorney’s fees. The petitioners’ liability was solidary.