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Auza Vs MOL Phils Inc

This case involves three employees - Dionisio Auza, Adessa Otarra, and Elvie Jaquet - who resigned from their positions at MOL Philippines, Inc. in 2002 after being informed that the company's Cebu branch would be closing down. The employees were paid separation benefits and signed quitclaim documents. However, they later filed complaints alleging illegal dismissal. The lower courts ruled in favor of MOL, finding that the employees had voluntarily resigned. The Supreme Court agrees, noting that the employees' resignation letters expressed gratitude and did not indicate any element of force or misrepresentation by the company. While quitclaim documents are generally against public policy, the Court upholds the validity of the documents signed by the

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128 views2 pages

Auza Vs MOL Phils Inc

This case involves three employees - Dionisio Auza, Adessa Otarra, and Elvie Jaquet - who resigned from their positions at MOL Philippines, Inc. in 2002 after being informed that the company's Cebu branch would be closing down. The employees were paid separation benefits and signed quitclaim documents. However, they later filed complaints alleging illegal dismissal. The lower courts ruled in favor of MOL, finding that the employees had voluntarily resigned. The Supreme Court agrees, noting that the employees' resignation letters expressed gratitude and did not indicate any element of force or misrepresentation by the company. While quitclaim documents are generally against public policy, the Court upholds the validity of the documents signed by the

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learning
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Dionisio F. Auza, JR., Adessa F. Otarra, and Elvie Jean Jaquet, Petitioners, v.

MOL Philippines,
Inc., et. al., GR. 175481, Nov. 21, 2012

Del Castillo, J.

Facts: Petitioners Dionisio F. Auza, Jr. (Auza), Adessa F. Otarra and Elvie Jeanjaquet
are employees of respondent MOL Philippines, Inc. (MOL). In 2002, Auza, et al.
submitted their resignation letters. Auza, et al. were then given their separation pay and
the monetary value of leave credits, 13th month pay, MOL cooperative shares and
unused dental/optical benefits. Afterwhich, they executed Release and Quitclaims and
then issued Separation Clearances.

In February 2004 or almost 15 months after their severance from employment, Auza,
et al. filed separate Complaints for illegal dismissal. Auza, et al. insist that they were not
given any choice but to resign after MOL informed them of the impending closure of
the branch and that they would not receive any separation pay if the closure would
precede their resignation. The LA dismissed their complaints.

On appeal, the NLRC ruled that Auza, et al. were illegally dismissed. Thus, MOL filed
a petition for certiorari before the Court of Appeals. The CA ruled in favor of MOL.

Issue: Did Auza, et al. voluntarily resign from employment?

Ruling: Yes. Resignation is the formal pronouncement or relinquishment of an office.


The overt act of relinquishment should be coupled with an intent to relinquish, which
intent could be inferred from the acts of the employee before and after the alleged
resignation.

It appears that petitioners, on their own volition, decided to resign from their positions
after being informed of the management’s decision that the Cebu branch would
eventually be manned by a mere skeletal force. Contrary to their assertions, petitioners
were not lured by any misrepresentation by respondents. Instead, they themselves were
convinced that their separation was inevitable and for this, they voluntarily resigned. As
aptly observed by the CA, no element of force can be deduced from their letters of
resignation as the same even contained expressions of gratitude and thus contradicting
their allegations that same were prepared by their employer.

Although quitclaims are generally against public policy, voluntary agreements entered
into and represented by a reasonable settlement are binding on the parties which may
not be later disowned simply because of a change of mind. "It is only where there is
clear proof that the waiver was wangled from an unsuspecting or gullible person, or the
terms of the settlement are unconscionable, that the law will step in to bail out the
employee." Hence, we uphold the validity of the quitclaims signed by petitioners in
exchange for the separation benefits they received from respondents.

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