G.R. No. 215627, June 5, 2017
LUIS S. DOBLE, JR., Petitioner, vs. ABB, INC./NITIN DESAI, Respondents

FACTS

Petitioner Luis S. Doble, Jr., a long-time employee of respondent ABB, Inc., rose to the position of Vice-President and Local Division Manager. His performance ratings were consistently strong or superior from 1993 until 2010. On March 13, 2012, he was summoned to a meeting where the company President and HR Manager informed him that due to losses and discontent in his division, global management demanded a leadership change. He was presented with the option to resign, with an offer of separation pay, and was given a short deadline to decide. Doble protested, stating he was confused and hungry. The HR Manager allegedly prevented him from leaving the premises to eat, instructed security not to allow him to exit, and pressured him to prepare a resignation letter that same day, stating he would not be permitted to return to the company otherwise. Doble, finding his computer access already revoked, drafted a resignation letter under these conditions. The HR Manager rejected his initial draft for including the phrase “as per your instruction” and instructed him to revise it to read as a voluntary tender of resignation, which he ultimately did.

ISSUE

Whether the petitioner was illegally constructively dismissed, rendering his resignation involuntary and void.

RULING

Yes, the Supreme Court ruled that Doble was illegally constructively dismissed. The legal logic centers on the doctrine of constructive dismissal, which occurs when an employee’s resignation, though ostensibly voluntary, is compelled by circumstances amounting to coercion, duress, or intolerable working conditions created by the employer. The Court found that the employer’s actions—suddenly confronting Doble with a demand to resign based on a new, unsatisfactory performance rating after years of positive reviews, confining him to the premises under threat, imposing an immediate deadline, cutting off his system access, and dictating the content of his resignation letter—collectively established that his will was overborne. The resignation was not an act of free will but a product of undue pressure, making it involuntary. Consequently, the termination, framed as a resignation, was illegal for lack of a just or authorized cause and for failure to observe substantive and procedural due process. The Court ordered his reinstatement with full backwages and awarded moral and exemplary damages due to the employer’s evident bad faith in orchestrating the dismissal.