Silvertex Weaving Corporaton vs. Campo
G.R. No. 211411, March 16, 2016
Respondent Teodora F. Campo claimed that she worked for Silvertex Weaving Corporaton (STWC) as a weaving machine operator. Prior to her dismissal, she was suspended for one week after a stitching machine that she was operating overheated and emitted smoke on. When she tried to report back to work, she was denied entry by the STWC’s security guard, reportedly upon the instructions of Arcenal.
For their defense, the petitioners argued that the respondent voluntarily resigned from STWC after she was reprimanded for poor job performance. They submitted a handwritten resignation letter allegedly executed by the respondent together with the Waiver, Release and Quitclaims Statement that she supposedly signed following her receipt of ₱30,000.00 from STWC. The respondent, however, denied having executed the resignation letter, the quitclaim, and the supposed receipt of the ₱30,000.00.
After finding merit in the documentary evidence presented by the petitioners, the Labor Arbiter rendered a Decision dismissing the complaint for lack of merit. Dissatisfied, the respondent appealed to the National Labor Relations Commission (NLRC).
The NLRC issued its Resolution initially granting the appeal. Upon Motion for Reconsideration, the NLRC however reinstated and affirmed in toto the decision of LA. It heavily considered a Questioned Document Report (QDR) from the Philippine National Police (PNP) Crime Laboratory, which purportedly indicated that upon examination, the disputed signatures on the resignation letter and quitclaim were written by the respondent. The burden to disprove the authenticity of the submitted documents allegedly fell upon the respondent, through evidence other than a bare denial.
Feeling aggrieved, the respondent filed with the CA a petition for certiorari, which was later granted by the CA. Hence, the petition.
Whether or not the resignation and quitclaim were valid
The SC denied the petition.
The employer has the burden of proving that the employee was not dismissed, or, if dismissed, that the dismissal was not illegal. The petitioners attempted to discharge the burden of proving the respondent’s resignation by referring mainly to a letter allegedly executed by the respondent.
There were conflicting findings in the PNP QDR. The report mentions that alleged resignation letter did not appear to be written by the same person who signed the several payroll slips and Philhealth records although it matched the supposed handwriting of the respondent in her bio-data.
Clearly then, given the vehement claim of the respondent that her signature on the resignation letter was a mere forgery, the evidence presented by the petitioners to establish their defense of voluntary resignation failed to suffice. Several other indicators cast doubt on the letter’s authenticity.
The authenticity and due execution of the undated Waiver, Release and Quitclaims Statement purportedly signed by the respondent was also not sufficiently established. The QDR was not conclusive on the issue of its genuineness. Even granting that such document was actually executed by the respondent, its execution was not fatal to the respondent’s case for illegal dismissal. The finding of illegal dismissal could still stand, as jurisprudence provides that “[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.