G.R. No. 221411, September 28, 2020
Italkarat 18, Inc., Petitioner, vs. Juraldine N. Gerasmio, Respondent.

FACTS

Respondent Juraldine Gerasmio filed a complaint for illegal dismissal against petitioner Italkarat 18, Inc. He alleged that in November 2008, the company’s officer-in-charge, Noel San Pedro, informed him of a planned retrenchment due to business losses. San Pedro offered him P170,000.00 for early retirement, cautioning that if he refused, he might be terminated later without receiving anything. Relying on this promise, Gerasmio executed a resignation letter and quitclaim on November 20, 2008. However, upon returning to collect his check, he was informed he would only receive P26,901.34. He then demanded the promised amount and, upon the company’s refusal, filed the complaint.
The company contended that Gerasmio voluntarily resigned in October 2008 to pursue a seaman’s job and demanded separation pay for his long service. He subsequently executed a quitclaim, received his computed last pay of P26,901.34, and only later demanded an additional P170,000.00 without basis. The Labor Arbiter ruled in favor of Gerasmio, finding illegal dismissal due to forced resignation based on a misrepresentation. The NLRC reversed this, finding voluntary resignation and a valid quitclaim. The Court of Appeals reinstated the Labor Arbiter’s decision, giving credence to Gerasmio’s claim of being induced to resign by the promise of a larger sum.

ISSUE

Whether respondent Juraldine Gerasmio was illegally dismissed or voluntarily resigned from his employment.

RULING

The Supreme Court ruled that Gerasmio voluntarily resigned and was not illegally dismissed. The Court emphasized that in termination disputes, the burden of proof rests on the employee to substantiate the claim of illegal dismissal. Gerasmio failed to discharge this burden. The sequence of events supported the company’s version; his resignation letter was dated October 20, 2008, predating the alleged November promise, which undermined his claim that the promise induced the resignation. The Court found the quitclaim valid, as it was executed for a reasonable consideration without proof of vitiated consent, such as fraud or deceit.
The legal logic centers on the principle that a resignation must be voluntary and with the intent to relinquish employment. The Court found Gerasmio’s act of submitting a resignation letter and executing a quitclaim for a computed amount demonstrated this voluntariness. His subsequent claim of a separate oral promise for P170,000.00 was unsubstantiated and belied by the documentary evidence. Since he failed to prove that his consent to the quitclaim was vitiated by fraud or that his resignation was involuntary, his claims for illegal dismissal and separation pay had no merit. The NLRC decision was thus reinstated.