GR 240254; (July, 2019) (Digest)
G.R. No. 240254 . July 24, 2019.
RODESSA QUITEVIS RODRIGUEZ, Petitioner, vs. SINTRON SYSTEMS, INC. AND/OR JOSELITO CAPAQUE, Respondents.
FACTS
Petitioner Rodessa Rodriguez was hired by respondent Sintron Systems, Inc. (SSI) as a Sales Coordinator on July 4, 2001. A conflict arose after Rodriguez attended a training in the USA in October 2013. Upon her return, SSI asked her to sign a training agreement requiring her to remain with the company for three years or pay a penalty, which she refused. In a meeting on November 18, 2013, respondent Joselito Capaque allegedly shouted vindictive words at her. Rodriguez then went on absences and filed leave requests. Capaque sent emails to clients stating Rodriguez had abandoned her job. On December 20, 2013, Capaque verbally informed her she was dismissed. Rodriguez filed a complaint for constructive illegal dismissal, non-payment of Service Incentive Leave (SIL) pay, separation pay, damages, and attorney’s fees.
SSI denied maltreatment and claimed Rodriguez was inefficient and disrespectful. SSI required her to share documents and email passwords upon her return, which she failed to do. SSI denied receiving her initial leave requests and later denied her subsequent leave requests. SSI discovered Rodriguez had deleted contents from her company email account and computer, constituting serious misconduct. The Labor Arbiter dismissed Rodriguez’s complaint, finding no constructive dismissal and that her actions constituted gross negligence. The NLRC affirmed but awarded SIL pay. The Court of Appeals denied both parties’ petitions, affirming the NLRC, finding neither dismissal nor abandonment, but noted reinstatement was not feasible due to strained relations.
ISSUE
1. Whether the Court of Appeals erred in finding that there was neither illegal dismissal nor abandonment.
2. Whether the Court of Appeals committed reversible error in finding that reinstatement is no longer feasible, hence, the parties must just bear their own losses.
RULING
The petition was denied. The Supreme Court held that the core question was one of factβwhether Rodriguez was illegally dismissed. In a Rule 45 petition assailing a CA decision in a labor case, the Court generally does not address questions of fact, except to determine if the CA correctly ruled that the NLRC did not commit grave abuse of discretion. The findings of fact by the Labor Arbiter, affirmed by the NLRC and the CA, are accorded finality and respect if supported by substantial evidence. The Court found no reason to deviate from these findings.
On the first issue, the Court agreed with the CA that Rodriguez failed to substantiate her claim of constructive dismissal. There was no evidence of unbearable working conditions forcing her to resign. Her absences were not justified, and SSI’s actions did not constitute overt acts of dismissal. The Court also agreed there was no abandonment, as Rodriguez filed a complaint immediately, indicating no intent to sever employment.
On the second issue, the Court affirmed that reinstatement was not feasible due to the strained relationship between the parties, as both parties made assertions showing damaged relations. Since there was no illegal dismissal, Rodriguez was not entitled to separation pay in lieu of reinstatement. The award of SIL pay by the NLRC and affirmed by the CA was sustained. The parties were left to bear their own losses.
