IN 2005, respondent Gloria Maquilan was employed by petitioner Carolina’s Lace Shoppe (CLS) as sales clerk.
In April 2008, the Department of Labor and Employment (Dole) inspected CLS. Upon inspection, one of the latter’s employees, Santiago A. Espultero, told the labor inspector that he was receiving a daily wage of P250. Thereafter, Espultero was dismissed from the service. One month thereafter, Maquilan was likewise dismissed for no reason given. Like Espultero, she was made to sign a quitclaim in order to claim her separation pay amounting to P15,000 despite her three years in service.
Maquilan filed a case for illegal dismissal with money claims and damages against CLS. In defense, CLS averred that Maquilan voluntarily resigned and that she offered no evidence which depicted that force or fraud was employed when her resignation letter with quitclaim was executed.
Is there merit to this defense?
Ruling: No.
Verily, the acts preceding and subsequent to the employee’s resignation must be taken into consideration.
Here, prior to her resignation, there was no indication that Maquilan intended to relinquish her employment. Such alleged resignation actually took place after the Dole conducted an inspection, which yielded to an information that CLS was not giving its employees their due wages. A month after such inspection, like the employee who reported such labor standards violation, Maquilan was separated from employment by virtue of a resignation letter. In this regard, there was no clear intention on the part of Maquilan to relinquish her employment.
In the case of Mobile Protective & Detective Agency, 497 Phil. 621, 630 (2005), this Court ruled that resignation letters which are in the nature of a quitclaim, lopsidedly worded to free the employer from liabilities, reveal the absence of voluntariness. Moreover, the quitclaim contained in the resignation letter does not contain stipulations required for its efficacy.
Admittedly, the quitclaim does not indicate that Maquilan received the amount of P15,000 as full and final settlement. Similarly, there was nothing which indicates that said amount constitutes said full and final settlement.
The quitclaim was also couched in general terms and the tenor of the same does not show that Maquilan understood the importance of the same considering that on the same day that she resigned, she immediately relieved respondents from their liabilities.
There was also no indication that Maquilan intends to give up her claimed benefits in consideration of a fixed compromise amount. It must be emphasized that Maquilan was constrained to receive the amount of P15,000.00 as she was eight months pregnant at that time and lives with no other means aside from her employment with CLS. (Carolina’s Lace Shoppe, et al. vs. Gloria Maquilan, et al., G.R. No. 219419, April 10, 2019).