The Supreme Court affirmed that in illegal dismissal cases, employers bear the burden of proving an employee’s voluntary resignation. This ruling underscores the importance of authentic documentation and credible evidence when employers claim an employee willingly left their job, protecting employees from potentially fabricated resignations used to avoid illegal dismissal claims.

When a Signature Sparks Suspicion: Unraveling an Illegal Dismissal Claim

This case revolves around Teodora F. Campo’s claim of illegal dismissal against Silvertex Weaving Corporation (STWC). Campo alleged she was unlawfully terminated after a suspension, while STWC argued she voluntarily resigned. The central issue was the authenticity of Campo’s resignation letter and quitclaim, which she vehemently denied signing. The Supreme Court scrutinized the evidence, particularly a questioned document report, to determine if STWC had adequately proven Campo’s resignation was indeed voluntary. The decision highlights the employer’s burden of proof in resignation claims and the impact of questionable documents on labor disputes.

The legal framework surrounding illegal dismissal places a significant responsibility on the employer. As the Supreme Court reiterated, “the employer has the burden of proving that the employee was not dismissed, or, if dismissed, that the dismissal was not illegal.” This principle is especially critical when an employer argues that an employee resigned voluntarily. The defense of resignation requires the employer to demonstrate that the employee intended to relinquish their position, and this intent must be clear and convincing. The case of San Miguel Properties Philippines, Inc. v. Gucaban further emphasizes this point:

Resignation – the formal pronouncement or relinquishment of a position or office – is the voluntary act of an employee who is in a situation where he believes that personal reasons cannot be sacrificed in favor of the exigency of the service, and he has then no other choice but to disassociate himself from employment. The intent to relinquish must concur with the overt act of relinquishment; hence, the acts of the employee before and after the alleged resignation must be considered in determining whether he in fact intended to terminate his employment. In illegal dismissal cases, fundamental is the rule that when an employer interposes the defense of resignation, on him necessarily rests the burden to prove that the employee indeed voluntarily resigned. x x x.

In this case, STWC attempted to meet this burden by presenting a resignation letter and a quitclaim, waiver, and release allegedly signed by Campo. However, Campo consistently denied the authenticity of these documents, claiming her signatures were forged. This denial shifted the focus to the credibility of the evidence presented by STWC. The Court of Appeals (CA) correctly pointed out that the NLRC’s reliance on the Questioned Document Report (QDR) from the PNP Crime Laboratory was flawed. While the NLRC interpreted the report as confirming the authenticity of Campo’s signature, a closer examination revealed conflicting findings. The QDR indicated that the signature on the resignation letter did not match Campo’s signatures on other documents, such as payroll slips and Philhealth records.

This discrepancy significantly undermined STWC’s claim of voluntary resignation. The PNP Crime Laboratory’s report stated:

FINDINGS:

x x x x

3. Scientific comparative examination and analysis of the questioned signature TEODORA CAMPO marked “Q-4” appearing on a Resignation letter and the submitted standard signatures of TEODORA CAMPO marked “S-l to S-17” inclusive reveal divergences in the manner of execution, line quality, stroke structures and other individual handwriting characteristics.

x x x x CONCLUSIONS:

x x x x

3. The questioned signature of TEODORA CAMPO marked “Q-4” appearing on the above mentioned documents and the submitted standard signatures of TEODORA CAMPO marked “S-1” to “S-17” inclusive WERE NOT WRITTEN BY ONE AND THE SAME PERSON.

The conflicting findings within the PNP report raised serious doubts about the letter’s authenticity. Although the report also mentioned a match with Campo’s signature on her bio-data, the fact that only one out of eighteen reference documents matched the signature on the resignation letter weakened STWC’s case. Moreover, there was no guarantee that the signature on the bio-data was genuinely Campo’s, further diminishing its reliability as a basis for comparison. The Court found that STWC failed to provide sufficient evidence to prove Campo’s voluntary resignation.

The importance of establishing the authenticity and due execution of documents in labor disputes cannot be overstated. The NLRC’s initial resolution highlighted several inconsistencies in the signatures on the resignation letter and other documents presented by STWC. These inconsistencies, coupled with Campo’s sworn denial of the signatures’ authenticity, cast further doubt on STWC’s claims. The Supreme Court agreed with the CA’s assessment that STWC failed to meet its burden of proof.

Even if the quitclaim, waiver, and release were proven to be authentic, the Court emphasized that this would not automatically negate the illegal dismissal claim. As established in Londonio, et al. v. Bio Research, Inc., et al, “[a]n employee’s execution of a final settlement and receipt of amounts agreed upon do not foreclose his right to pursue a claim for illegal dismissal.” This principle recognizes that employees may sometimes sign such documents under duress or without fully understanding their rights.

The Supreme Court ultimately upheld the CA’s finding that Campo was illegally dismissed. This decision serves as a reminder to employers of their burden of proof in resignation cases and the importance of presenting credible evidence. The case also highlights the potential pitfalls of relying on questionable documents and the need for thorough investigation and verification in labor disputes. The court modified the interest rate computation to align with current jurisprudence, specifying that the 6% per annum interest would be computed from the date the resolution becomes final and executory, until full payment, in accordance with the guidelines set forth in Nacar v. Gallery Frames.

FAQs

What was the key issue in this case?	The key issue was whether the employee, Teodora F. Campo, voluntarily resigned or was illegally dismissed by Silvertex Weaving Corporation. The determination hinged on the authenticity of a resignation letter and quitclaim presented by the employer.
Who has the burden of proof in illegal dismissal cases?	In illegal dismissal cases, the employer bears the burden of proving that the employee was not dismissed or that the dismissal was for a just cause. If the employer claims the employee resigned, they must prove the resignation was voluntary.
What is the significance of a Questioned Document Report (QDR) in this case?	The QDR from the PNP Crime Laboratory was crucial because it analyzed the authenticity of the employee’s signature on the resignation letter. The conflicting findings in the report ultimately weakened the employer’s claim of voluntary resignation.
Can a quitclaim prevent an employee from pursuing an illegal dismissal claim?	No, an employee’s execution of a quitclaim does not automatically prevent them from pursuing a claim for illegal dismissal. The circumstances surrounding the signing of the quitclaim are considered to determine its validity.
What did the Court rule regarding the interest on the monetary award?	The Court modified the CA’s decision, ruling that the 6% interest per annum on the total monetary award should be computed from the date the Supreme Court’s resolution becomes final and executory until full payment.
What evidence did the employer present to prove voluntary resignation?	The employer presented a resignation letter and a quitclaim, waiver, and release allegedly signed by the employee. They also submitted a Questioned Document Report to support the authenticity of the signatures.
What was the employee’s defense against the employer’s claim of resignation?	The employee consistently denied the authenticity of the resignation letter and quitclaim, claiming that her signatures were forged. She maintained that she had no intention of resigning from her employment.
What factors did the Court consider in determining whether the resignation was voluntary?	The Court considered the conflicting findings of the QDR, inconsistencies in the signatures on the documents, the employee’s denial of the signatures’ authenticity, and the lack of conclusive evidence to support the employer’s claim.

This case provides critical guidance on the evidence needed to prove voluntary resignation and underscores the importance of thorough documentation and verification in employment termination cases. The decision emphasizes that employers must bear the burden of proving an employee’s voluntary resignation with clear, convincing, and authentic evidence, particularly when the employee disputes the authenticity of critical documents.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Silvertex Weaving Corporation vs. Teodora F. Campo, G.R. No. 211411, March 16, 2016