The Supreme Court (SC) has ruled that demotion, verbal abuse, and hostile behavior by an employer leading an employee to resign, constituted constructive illegal dismissal.
The Supreme Court shared this on their official Instagram page on the afternoon of September 27, 2024.
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This is highlighted by a ruling by the SC Second Division authored by Associate Justice Amy C. Lazaro-Javier on April 3, 2024, regarding the case of a certain ‘Jonathan’, who was constructively terminated from his job at an auto dealership in Quezon City.
Documents reveal that ‘Jonathan’ became a regular employee in 2010, and was in charge of car sales in addition to other goods and services. The senior management of the company reportedly treated him badly while he was still employed with them.
‘Jonathan’’s frequent absences in 2015 resulted in a seven-day suspension. He was accompanied by his sibling, who served as his legal representative, at a meeting with the management. He said that the company president publicly humiliated him for inviting his sibling to the meeting.
Later on, he was moved to a different team, and several of his accounts were deleted without explanation. A general manager turned down his attempt to process a sale, and his new employer directly inquired about his resignation plans.
‘Jonathan’ resigned in 2016 due to the hostile work environment he was in. In attempts to get his clearance, he was harassed for no reason and was treated like a criminal. He then filed a lawsuit for constructive dismissal and money claims against the corporation and its personnel with the Labor Arbiter (LA).
According to the LA’s ruling in favor of Bartolome, constructive dismissal occurred because of the substantial role that his transfer to another team played in his resignation. The ruling of the LA was affirmed by the National Labor Relations Commission (NLRC). Nevertheless, he resigned voluntarily, and the Court of Appeals (CA) did not find any evidence of coercion or intimidation, ruling in favor of the auto company.
The Supreme Court ruled ‘Jonathan’’s favor. It stressed that behaviors that show intense hostility and distaste, like demoting, uttering insulting words, and acting indifferent toward an employee, qualify as constructive illegal dismissal when they make working conditions so terrible that resigning is the only option.
As per the Court’s ruling, the standard for constructive dismissal is whether or not a reasonable person in the employee’s position would have felt pressured to resign under similar circumstances.
Although the Court stated that there will inevitably be arguments at work and harsh words may be exchanged, these should not diminish the dignity of employees in order to prevent a hostile work environment.
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