MANOLO A. PEAFLOR vs.

OUTDOOR CLOTHING MANUFACTURING CORPORATION

(G.R. No. 177114. January 21, 2010)

FACTS: Peaflor was hired on September 2, 1999 as probationary HRD Manager of respondent
Outdoor Clothing Manufacturing Corporation. Peaflor claimed that his relationship with Outdoor
Clothing went well during the first few months of his employment. His woes began when the
companys Vice President for Operations, Edgar Lee, left the company after a big fight between Lee
and Chief Corporate Officer Nathaniel Syfu. Because of his close association with Lee, Peaflor
claimed that he was among those who bore Syfus ire. After Peaflor returned from his field work on
March 13, 2000, his officemates informed him that while he was away, Syfu had appointed
Nathaniel Buenaobra as the new HRD Manager. He tried to talk to Syfu to clarify the matter, but was
unable to do so. Peaflor claimed that under these circumstances, he had no option but to resign.
He submitted a letter to Syfu declaring his irrevocable resignation from his employment with
Outdoor Clothing effective at the close of office hours on March 15, 2000. Peaflor then filed a
complaint for illegal dismissal with the labor arbiter, claiming that he had been constructively
dismissed. Outdoor Clothing denied Peaflors allegation of constructive dismissal. It posited instead
that Peaflor had voluntarily resigned from his work. The labor arbiter agreed with Penaflor and
issued a decision in his favor. On appeal, the NLRC reversed the arbiters decision and the CA
affirmed the NLRCs decision. Hence, petitioner filed a petition for review before the SC.

ISSUE: Can Peaflors resignation be considered as constructive dismissal equivalent to an illegal

dismissal?

RULING: Yes. Peaflor started working for the company on September 2, 1999 so that by March 1,
2000, his probationary period would have ended and he would have become a regular employee.
We find it highly unlikely that he would resign on March 1 and would simply leave given his
undisputed record of having successfully worked within his probationary period. It does not appear
sound and logical to us that an employee would tender his resignation on the very same day he was
entitled by law to be considered a regular employee, especially when a downsizing was taking place
and he could have availed of its benefits if he would be separated from the service as a regular
employee. It was strange, too, that he would submit his resignation on March 1 and keep quiet
about this until its effective date on March 15. In our view, it is more consistent with human
experience that Peaflor indeed learned of the appointment of Buenaobra only on March 13, 2000
and reacted to this by tendering his resignation letter after realizing that he would only face hostility
and frustration in his working environment. Three very basic labor law principles support this
conclusion and militate against the companys case.

The first is the settled rule that in employee termination disputes, the employer bears the burden of
proving that the employees dismissal was for just and valid cause. That Peaflor did indeed file a
letter of resignation does not help the companys case as, other than the fact of resignation, the
company must still prove that the employee voluntarily resigned. There can be no valid resignation
where the act was made under compulsion or under circumstances approximating compulsion, such
as when an employees act of handing in his resignation was a reaction to circumstances leaving him
no alternative but to resign. In sum, the evidence does not support the existence of voluntariness in
Peaflors resignation.
Another basic principle is that expressed in Article 4 of the Labor Codethat all doubts in the
interpretation and implementation of the Labor Code should be interpreted in favor of the
workingman. Thus, we find that Peaflor was constructively dismissed given the hostile and
discriminatory working environment he found himself in, particularly evidenced by the escalating
acts of unfairness against him that culminated in the appointment of another HRD manager without
any prior notice to him. Where no less than the companys chief corporate officer was against him,
Peaflor had no alternative but to resign from his employment.

Last but not the least, we have repeatedly given significance in abandonment and constructive
dismissal cases to the employees reaction to the termination of his employment. We find from the
records that Peaflor sought almost immediate official recourse to contest his separation from
service through a complaint for illegal dismissal. This is not the act of one who voluntarily resigned;
his immediate complaints characterize him as one who deeply felt that he had been wronged.