Cases: Resignation

1. Concept and effects of tendering a resignation letter

Philippine National Construction Corporation v. NLRC, PNCC Toll Operations Employees and Workers Union (PNCC-TOEWU)

G.R. No. 117240, 02 October 1997

[The employer] and [the Company Union] entered into a Collective Bargaining Agreement far a period of five (5) years from February 1, 1990 to January 30, 1995. It is provided in the collective bargaining agreement (CBA) that a mid-year bonus shall be granted to the employees who are covered by the bargaining unit as of June 1 of the covered year, viz.:

Sec. 2. Mid-Year Bonus — The COMPANY agrees to grant to all the employees covered by the bargaining unit a mid-year bonus of one (1) month basic salary to be given on or before June 1, each year. The mid-year bonus for 1990 shall be granted to employees who are covered by the bargaining unit including those employees who already attained the status of a regular employee as of June 1, 1990.

Due to financial difficulties, however, between April and May, 1991, [the employer] implemented a Voluntary Separation Program. The individual complainants took advantage of the offer and, after signing individual quitclaims, were paid an equivalent of one-and-a-half month’s pay for every year of credited service as well as a 30-day advance salary. Consequently, they were not given any mid-year bonus because as of June 1, 1991, [the employer] no longer considered them as its employees.

[The Labor Arbiter ruled in favor of...

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