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The Supreme Court says constructive dismissal is committed when an employer ‘creates unbearable working conditions’ which force employees to resign
MANILA, Philippines – The Supreme Court (SC) said in its recent ruling that the insults and hostility of employers that forced employees to resign is illegal.
In the SC Second Division’s decision penned by Associate Justice Amy Lazaro-Javier, the High Court said constructive dismissal is committed when an employer “creates unbearable working conditions” like demotion, verbal abuse, and hostile behavior against their employees, forcing them to resign.
The High Court’s ruling stemmed from a case involving a certain Jonathan Dy Chua Bartolome, who was constructively dismissed by Toyota Quezon Avenue, Inc. (TQAI). Bartolome, who was employed to sell cars, products, and services, faced hostility from the company’s senior management when he was still with Toyota, the SC said.
In 2015, the worker was suspended for seven days for frequently absenting from work. During a meeting with the company’s management, Bartolome brought his sibling who served as his legal counsel. However, the company president humiliated the employee for being accompanied by his sibling.
Bartolome was also transferred to another team and his accounts were also taken away from him without explanation from the management. When he attempted to process a sale, the company’s general sales manager turned it down.
He was also asked by his new boss, explicitly, if he was planning to resign, the SC added.
Citing these events and his hostile work environment, Bartolome resigned in 2016. The SC said when the employee tried getting his clearance, “he was treated like a stranger-criminal and harassed for no reason.”
This pushed Bartolome to file a complaint with Labor Arbiter (LA) against the company’s officials. Later, the arbiter ruled that the employee was constructively dismissed and that the “circumstances leading to his transfer to another team largely contributed to his resignation.”
When the case reached the National Labor Relations Commission, it affirmed the LA’s decision favoring Bartolome. However, when the case reached the Court of Appeals, the court ruled in Toyota’s favor and found that Bartolome “voluntarily resigned” and failed to prove that his withdrawal from the company was not because of coercion and intimidation.
This prompted Bartolome to bring his case to the High Court.
“The Supreme Court ruled in favor of Bartolome. It emphasized that actions demonstrating extreme dislike and hostile behavior, such as demotion, uttering insulting words, and apathetic behavior toward an employee, constitute constructive illegal dismissal when such actions cause the employment conditions to be so unbearable that there is no other choice but to resign,” the High Court said.
In the ruling, the SC that although strong words may be said in the workplace, “these should not degrade the dignity of employees to avoid a hostile work environment.” The High Court said the company senior officials’ attitude toward Bartolome showed “extreme dislike and hostile behavior.”
“These actions collectively indicated that they were pushing Bartolome out, leaving him with no choice but to resign from his employment…. Bartolome would not have intended to resign from the company without TQAI officials’ hostile actions,” the SC added.
The SC also ordered the company and its officials to pay Bartolome’s full backwages, separation pay, earned commissions, moral and exemplary damages, and attorney’s fees. – Rappler.com
