The Supreme Court has ruled that resignation caused by verbal abuse, indifferent behavior, and demotion constitutes constructive illegal dismissal, affirming that such acts create intolerable work conditions that force employees to resign.
In a decision by the Supreme Court’s Second Division, Associate Justice Amy Lazaro-Javier upheld the case of Jonathan Dy Chua Bartolome, a car dealer employee from Quezon City, who was deemed constructively dismissed after being subjected to humiliating treatment and job demotion.
Bartolome began working as a regular employee in 2010, tasked with selling vehicles, products, and services. However, after repeated absences, he was suspended for seven days.
During a management meeting, Bartolome was accompanied by his brother, who acted as his legal counsel.
The company president reportedly embarrassed Bartolome for bringing his brother to the meeting.
Subsequently, Bartolome was reassigned to another team, with many of his accounts removed without explanation.
The Supreme Court detailed that the company’s general sales manager further obstructed Bartolome’s sales efforts, and his superior asked if he was planning to resign.
Feeling forced into a corner, Bartolome resigned in 2016.
When Bartolome attempted to secure his clearance, he was allegedly treated like a criminal and subjected to harassment without cause.
As a result, he filed a complaint with the Labor Arbiter, accusing the company and its officials of constructive dismissal.
Both the Labor Arbiter and the National Labor Relations Commission (NLRC) ruled in favor of Bartolome.
However, the Court of Appeals overturned the decision, stating that Bartolome voluntarily resigned and failed to prove coercion or intimidation.
In the final ruling, the Supreme Court sided with Bartolome, emphasizing that the combination of insults, demotion, and unjust treatment amounted to constructive illegal dismissal.
The SC added that workplace misunderstandings may occur, but employees’ dignity should never be compromised.
The court further stated that Bartolome would not have resigned if not for the aggressive actions and mistreatment by the car dealer’s management.
