G.R. No. 211411 , March 16, 2016
SILVERTEX WEAVING CORPORATION/ARMANDO ARCENAL/ROBERT ONG, PETITIONERS, VS. TEODORA F. CAMPO, RESPONDENT.

FACTS

The case stems from a complaint for illegal dismissal filed by Teodora F. Campo against Silvertex Weaving Corporation (STWC) and its officers. Campo claimed she worked as a weaving machine operator starting June 11, 1999, until she was unlawfully dismissed on November 21, 2010. She was suspended for one week starting November 14, 2010, after a machine she operated overheated. When she attempted to return to work on November 21, 2010, she was denied entry by the security guard upon instructions of petitioner Armando Arcenal.
The petitioners argued that Campo, hired only in June 2009, voluntarily resigned after being reprimanded for poor performance. They submitted a handwritten resignation letter allegedly dated November 13, 2010, and a Waiver, Release and Quitclaim Statement, claiming she received P30,000.00. Campo denied executing these documents and receiving any payment.
The Labor Arbiter dismissed Campo’s complaint, crediting the petitioners’ documentary evidence. On appeal, the NLRC initially reversed the decision, finding the signatures on the documents appeared to be forgeries and that Campo was constructively dismissed. However, upon the petitioners’ motion for reconsideration, which included a Questioned Document Report (QDR) from the PNP Crime Laboratory, the NLRC reinstated the Labor Arbiter’s decision. The QDR purportedly indicated the disputed signatures were genuine.
Campo filed a petition for certiorari with the Court of Appeals. The CA granted the petition, reinstating its modified version of the NLRC’s initial resolution finding illegal dismissal, increasing moral damages, and imposing legal interest.

ISSUE

Whether the Court of Appeals erred in ruling that the respondent was illegally dismissed, despite the documentary evidence (resignation letter and quitclaim) and the PNP Crime Laboratory report presented by the petitioners.

RULING

The Supreme Court DENIED the petition and AFFIRMED the CA Decision with modification regarding the computation of interest.
The Court held that in illegal dismissal cases, the burden of proof rests on the employer to prove that the employee voluntarily resigned. The petitioners failed to discharge this burden. The Court found the NLRC’s reliance on the PNP QDR to prove the authenticity of the resignation letter was misplaced. The full QDR report actually stated that the questioned signature on the resignation letter (“Q-4”) and the submitted standard signatures (“S-1” to “S-17”) “WERE NOT WRITTEN BY ONE AND THE SAME PERSON.” Although the report noted a match with a bio-data signature, the conflicting findings and the fact that only one of eighteen reference documents matched cast doubt on the letter’s authenticity. The respondent’s consistent denial of the signatures, coupled with the NLRC’s own initial observation that the signatures appeared forged and the petitioners’ failure to present the documents during conciliation, supported the conclusion that the documents were fabricated. Therefore, the petitioners’ defense of voluntary resignation failed. The respondent was illegally dismissed. The Court modified the CA ruling by ordering that the 6% per annum interest on the monetary award be computed from the finality of its Resolution, not from the date of dismissal.