GR 219419; (April, 2019) (Digest)
G.R. No. 219419 , April 10, 2019
Carolina’s Lace Shoppe, Lourdes Ragas and Claudine Mangasing, Petitioners, vs. Gloria Maquilan and Joy Maquilan, Respondents.
FACTS
Gloria Maquilan and her daughter Joy were employed by Carolina’s Lace Shoppe (CLS) as a sales clerk and header, respectively. In April 2008, a DOLE inspection occurred, after which an employee who spoke with the inspector was terminated and made to sign a quitclaim for separation pay. Subsequently, Gloria was dismissed without reason and, to receive ₱15,000.00 as separation pay, was allegedly compelled to sign a quitclaim despite three years of service. Joy suffered the same fate, receiving only ₱4,000.00. They filed a complaint for illegal dismissal with money claims. CLS, in defense, presented purported resignation letters and quitclaims as evidence of voluntary resignation. The Labor Arbiter ruled in favor of the Maquilans, finding illegal dismissal. The NLRC reversed, crediting the resignation documents. The Court of Appeals then reinstated the Labor Arbiter’s decision, finding the resignations and quitclaims involuntary.
ISSUE
Whether or not Gloria Maquilan and Joy Maquilan were illegally dismissed from employment.
RULING
Yes, the employees were illegally dismissed. The Supreme Court denied the petition and affirmed the CA decision. The burden of proving voluntary resignation rests on the employer. The Court scrutinized the circumstances surrounding the execution of the resignation letters and quitclaims. For Gloria, her immediate filing of a complaint for illegal dismissal the day after her alleged resignation, coupled with her claim of being forced to sign the documents to receive separation pay, negated any intent to sever employment. For Joy, the document she signed was a pre-printed quitclaim form where the entries, including the resignation portion, were written in the same handwriting as the computation of her pay, indicating it was prepared by the company and she was merely asked to sign.
The Court emphasized that notarization does not guarantee validity and the presumption of regularity can be rebutted. Here, the employees denied appearing before a notary, did not understand the documents’ effects, and the consideration received was grossly disproportionate to their years of service (₱15,000 for three years and ₱4,000 for one year). These factors, taken together with the suspicious timing following the DOLE inspection, established that the resignations were not voluntary but were secured under coercive circumstances. Consequently, the termination, lacking just or authorized cause and due process, was illegal. The employer’s failure to discharge its burden of proving a valid resignation resulted in a finding of illegal dismissal, entitling the employees to reinstatement or separation pay and backwages.