In the case of Flordaliza Llanes Grande v. Philippine Nautical Training College, the Supreme Court addressed the issue of forced resignation, emphasizing the employer’s burden to prove that an employee’s resignation was indeed voluntary. The Court found that Grande was illegally dismissed because her resignation was not a voluntary act but was obtained through undue influence. This decision highlights the importance of protecting employees from coercive tactics that deprive them of their right to security of tenure, reinforcing the principle that any doubt must be resolved in favor of the working person.

Quitting or Pushed Out? Unpacking a Claim of Forced Resignation

The case revolves around Flordaliza Llanes Grande, who worked at the Philippine Nautical Training College (PNTC). After resigning in 2007 for personal reasons, she was re-employed in 2009 as Director for Research and Course Department, later becoming Assistant Vice-President (VP) for Training Department. In February 2011, after anomalies were discovered in the Registration Department, Grande was called to a meeting on March 1, 2011, and told to resign. Assured of absolution from alleged involvement in the anomalies if she resigned, she submitted a resignation letter that same day. Believing she was unjustly forced to resign, Grande filed a police blotter for unjust vexation against Frederick Pios, the VP for Corporate Affairs, and subsequently filed a complaint for illegal dismissal.

The central legal question was whether Grande’s resignation was voluntary, or if it constituted illegal dismissal. The Labor Arbiter (LA) ruled in favor of Grande, finding that she was indeed forced to resign. The National Labor Relations Commission (NLRC) affirmed this decision. However, the Court of Appeals (CA) initially sided with the labor bodies, then reversed its stance upon reconsideration, dismissing Grande’s complaint. The Supreme Court, after careful consideration of the facts and circumstances, ultimately sided with Grande.

The Supreme Court emphasized that when an employer claims an employee resigned voluntarily, the burden of proof lies with the employer. They must present clear, positive, and convincing evidence that the resignation was indeed voluntary. The Court referred to the case of D.M. Consunji Corporation v. Bello, stating:

For the resignation of an employee to be a viable defense in an action for illegal dismissal, an employer must prove that the resignation was voluntary, and its evidence thereon must be clear, positive and convincing. The employer cannot rely on the weakness of the employee’s evidence.

The Court scrutinized the circumstances surrounding Grande’s resignation. Notably, the employer was silent regarding the alleged meeting on March 1, 2011, where Grande was asked to resign. The LA and the NLRC pointed out that neither Pios nor Atty. Hernani Fabia, the PNTC President, submitted affidavits to deny the meeting. Instead, the respondent claimed that Grande “suddenly and without reason tendered her resignation.” However, the Supreme Court found inconsistencies in the respondent’s statements. Initially, PNTC claimed the anomalies were discovered after the resignation, but later asserted Grande was confronted with discrepancies before she resigned. This contradiction cast doubt on the veracity of the employer’s defense.

The Court also questioned why PNTC immediately cleared Grande, despite an ongoing investigation into possible involvement of high-ranking officers in the anomalous transactions. Considering Grande was the Assistant Vice-President for the Training Department, the rapid clearance was deemed illogical. As the NLRC observed, if Grande was under investigation, her clearance should have been withheld until all liabilities were settled. This haste in clearing Grande suggested that the employer wanted her to leave. The Court found this especially compelling, reinforcing the notion that Grande’s departure was not entirely of her own volition.

Resignation, according to jurisprudence, is a voluntary act where an employee believes personal reasons outweigh the demands of their job, leaving them no choice but to leave. It must be a formal, unconditional relinquishment of office, made with the intention of relinquishing the position. The Supreme Court, citing Fortuny Garments/Johnny Co v. Castro, elucidated this point:

Resignation is the voluntary act of an employee who is in a situation where one believes that personal, reasons cannot be sacrificed in favor of the exigency of the service, and has no other choice but to dissociate from employment. Resignation is a formal pronouncement or relinquishment of an office, and must be made with the intention of relinquishing the office accompanied by the act of relinquishment. A resignation must be unconditional and with the intent to operate as such.

Here, the Supreme Court highlighted several factors indicating undue influence. First, Grande’s resignation letter was terse, suggesting it was written hastily and unwillingly. Second, she was actively preparing for an upcoming visit from the Maritime Training Council and had recently requested new textbooks. These actions were inconsistent with a voluntary decision to resign. Third, she filed a police blotter the same evening and an illegal dismissal complaint the following day. The Court also found the conversation between Pios and Grande indicative of pressure from management for her to resign. Drawing from Article 1337 of the Civil Code, the Court discussed the concept of undue influence:

Art. 1337. There is undue influence when a person takes improper advantage of his power over the will of another, depriving the latter of a reasonable freedom of choice. The following circumstances shall be considered; the confidential, family, spiritual, and other relations between the parties, or the fact that the person alleged to have been unduly influenced was suffering from mental weakness, or was ignorant or in financial distress.

The Supreme Court acknowledged that while Pios’s language did not involve overt threats, the circumstances suggested undue influence. He conveyed the management’s desire for Grande’s resignation, effectively depriving her of a genuine choice. The Supreme Court affirmed the NLRC’s ruling that Grande’s actions before and after the resignation demonstrated that undue force had been applied. These actions included filing a police report and subsequently filing the illegal dismissal case. Such prompt action was a telling sign of her intent. In fact, the Supreme Court referenced Valdez v. NLRC and Fungo v. Lourdes School of Mandaluyong:

x x x It would have been illogical for herein petitioner to resign and then file a complaint for illegal dismissal. Resignation is inconsistent with the filing of the said complaint.

Consequently, the Supreme Court emphasized that the element of voluntariness was missing from Grande’s resignation. By promptly pursuing her legal action, she clearly demonstrated her intention not to relinquish her employment. This was viewed as wholly incompatible with the assertion that she voluntarily resigned. Thus, the Supreme Court reversed the CA’s Amended Decision and reinstated the NLRC’s decision, with the modification of including backwages and attorney’s fees.

FAQs

What was the key issue in this case?	The key issue was whether Flordaliza Grande’s resignation from Philippine Nautical Training College (PNTC) was voluntary or considered an illegal dismissal due to undue influence from her employer. The Court had to determine if PNTC had proven that Grande’s resignation was a voluntary act on her part.
What is the employer’s responsibility in cases of alleged forced resignation?	The employer has the burden to prove that the resignation was voluntary. This requires clear, positive, and convincing evidence demonstrating that the employee willingly resigned, without coercion or undue influence.
What factors did the court consider in determining whether the resignation was voluntary?	The court considered the circumstances surrounding the resignation, including the employee’s actions before and after the resignation, the content of the resignation letter, and any evidence of pressure or undue influence from the employer. In this case, the court noted the terseness of the resignation letter, the employee’s ongoing work preparations, and the immediate filing of a police report and illegal dismissal case.
What does the legal principle of undue influence mean?	Undue influence, as defined in Article 1337 of the Civil Code, occurs when a person takes improper advantage of their power over another, depriving them of reasonable freedom of choice. This involves considering the relationships between the parties, and whether the influenced party was suffering from any vulnerability that was exploited.
What is the significance of filing a complaint for illegal dismissal shortly after resigning?	Filing a complaint for illegal dismissal soon after resigning suggests that the employee did not voluntarily leave their job. This is because it is illogical for an employee who willingly resigned to then claim they were illegally dismissed, indicating the resignation was not voluntary but forced.
How does this ruling affect employees who feel pressured to resign?	This ruling provides a legal basis for employees who feel pressured to resign to challenge their resignation as an illegal dismissal. It reinforces the importance of employers acting in good faith and ensuring that resignations are genuinely voluntary, protecting the rights of employees to security of tenure.
What remedies are available to an employee who is found to be illegally dismissed?	Under Article 279 of the Labor Code, an employee unjustly dismissed is entitled to reinstatement to their former position, full backwages, and other benefits. This aims to restore the employee to the position they would have been in had the illegal dismissal not occurred.
What evidence can an employee use to prove that their resignation was involuntary?	Employees can use various forms of evidence such as written communications, testimonies from witnesses, records of actions taken immediately after the resignation (like filing a police report), and any documentation indicating that the resignation was coerced or not genuinely voluntary. The totality of circumstances will be considered by the court.

The Supreme Court’s decision serves as a reminder that employers must act with transparency and fairness in all employment matters, particularly when it comes to an employee’s separation from service. This case underscores the judiciary’s commitment to protecting the rights of employees and ensuring that their decisions to leave employment are genuinely voluntary and free from coercion.

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: FLORDALIZA LLANES GRANDE VS. PHILIPPINE NAUTICAL TRAINING COLLEGE, G.R. No. 213137, March 01, 2017