GR 243951; (January, 2021) (Digest)
G.R. No. 243951 . January 20, 2021.
RAYMOND D. JACOB, JOERY L. SITJAR, AYAN C. GABRIEL, GREGORIO B. BALATON, LAWRENCE ALBERT N. INSIGNE, AND DENNIS L. TALAMANTE, PETITIONERS, VS. VILLASERAN MAINTENANCE SERVICE CORP. AND MARIA ANTONIA V. MERCADO, RESPONDENTS.
FACTS
Petitioners were employees of respondent Villaseran Maintenance Service Corp., a manpower service provider, assigned as janitors and electricians at Manila Central University Hospital (MCU). On January 31, 2016, MCU terminated its contract with Villaseran. Respondents assured petitioners of new assignments with a new principal. In February 2016, respondent Mercado, Villaseran’s general manager, instructed petitioners to draft handwritten resignation letters and sign Release and Quitclaim forms, purportedly as a formal requirement for their reassignment and to receive their last pay and benefits from MCU, which they complied with. After almost two months without any reassignment, petitioners filed a complaint for illegal dismissal, claiming the resignation letters were products of deceitful representations and false promises. Respondents countered that petitioners voluntarily resigned, as evidenced by the handwritten resignation letters and signed quitclaims, and that petitioners never asked for reinstatement; during mediation, respondents offered reinstatement but petitioners refused.
ISSUE
Whether petitioners were illegally dismissed or voluntarily resigned from their employment.
RULING
The Supreme Court ruled that petitioners were illegally dismissed. The resignation letters and quitclaims were not voluntarily executed but were obtained through respondents’ deceitful scheme. Respondents failed to prove that the resignations were voluntary. The assurance of reassignment was a false promise that vitiated petitioners’ consent. The subsequent offer of reinstatement during mediation was a mere afterthought and did not cure the illegal dismissal. Petitioners are entitled to full backwages, separation pay in lieu of reinstatement, and attorney’s fees. The awards are subject to legal interest.