G.R. No. 206316 March 20, 2019
Panasonic Manufacturing Philippines Corporation (formerly Matsushita Electric Philippines Corp.), Petitioner vs. John Peckson, Respondent

FACTS

Respondent John Peckson, a Sales Supervisor, submitted a resignation letter dated September 16, 2003, effective October 30, 2003, and a subsequent letter dated September 25, 2003, moving the effectivity to October 15, 2003. He completed exit procedures, including an interview and a quitclaim. However, on April 11, 2005, he filed a complaint for constructive dismissal. He alleged he was forced to resign after being accused by his manager, Jose De Jesus, of falsifying a signature on a travel authority. Peckson claimed he secured a PNP report exonerating him, but De Jesus disregarded it and threatened termination, compelling his resignation.
The Labor Arbiter and the National Labor Relations Commission (NLRC) dismissed the complaint, finding the resignation voluntary based on the clear tenor of the letters and his participation in exit formalities. The Court of Appeals (CA) reversed, ruling the company failed to prove the resignation was voluntary and that Peckson was constructively dismissed, entitling him to backwages and separation pay.

ISSUE

Whether the Court of Appeals erred in ruling that respondent John Peckson was constructively dismissed.

RULING

Yes, the Supreme Court reversed the CA and reinstated the NLRC decision. The Court held that resignation, being a voluntary act, must be proved by the employee claiming it was involuntary. The burden of proof rests upon the employee to show that the resignation was not voluntary and was actually a case of constructive dismissal. In this case, Peckson failed to discharge this burden.
The legal logic is anchored on the principle that resignation is characterized by an intent to relinquish employment, discernible from written documents and attendant circumstances. Peckson’s two unequivocal resignation letters, his proactive change of the effectivity date for personal reasons, and his willing compliance with all clearance procedures constitute clear and convincing evidence of voluntariness. His claim of a threat was uncorroborated and belied by the 18-month delay in filing the complaint, which is inconsistent with the behavior of an aggrieved employee. The manager’s alleged accusation and the PNP report do not, by themselves, establish coercion that vitiated consent, especially when juxtaposed with Peckson’s own deliberate actions. The findings of the LA and NLRC on these factual matters are accorded respect and finality.