Saudi Arabian Airlines v. Castells (2025)
Saudi Arabian Airlines v. Castells, G.R. No. 245269, July 28, 2025, Per Dimaampao, J.:
1. Background
• Maria Joy Teresa O. Bilbao (Bilbao), Castells, and Centi-Mandanas were hired by Saudia on May 13, 1986 as flight attendants. Years after into their employment with Saudia, Saddik received an inter-office memorandum dated August 18, 2004 from Saudia’s head office directing the transfer of the three crew members from Manila to Jeddah due to operational requirements…
• As it happened, Castells submitted her resignation letter on September 1, 2004. Four days later, Saudia, through Saddik, accepted her resignation, effective September 30, 2004. Bilbao and Centi-Mandanas followed suit and tendered their resignations on September 7, 2004. They both executed their respective quitclaims on October 28, 2004, acknowledging that they had received the full and complete end-of-service award, along with the final settlement, and had no further claims against Saudia. In the case of Castells, Bilbao signed a quitclaim on her behalf.
• On July 20, 2005, Castells and Bilbao lodged a complaint for illegal constructive dismissal against Saudia and Saddik, stating that they were forced to resign. On August 3, 2005, Centi-Mandanas also filed a complaint of the same cause of action against Saudia and Saddik, claiming that she was forced to resign.
• In her sworn statement, Castells recounted the following, among others:
1) She had worked for nearly 19 years with Saudia, earning multiple citations and commendations for excellent service.
2) On August 25, 2004, she was informed by their acting group supervisor, Faiza Hussein (Hussein), that she was on the list of flight attendants to be transferred from Manila to Jeddah starting in the first week of September 2004.
3) It was widely known among Saudia employees that when flight attendants of other nationalities were transferred to Jeddah due to “operational requirements,” they were essentially compelled to resign.
4) She reluctantly wrote her resignation letter, expressing gratitude for her work experience, as she felt she had no alternative but to resign in order to avoid the public embarrassment and stigma of being terminated.
5) Her employment was being terminated due to her being 39 years old.
• For herself, Centi-Mandanas attested—
1) She had dedicated almost 19 years to Saudia, during which time she received several citations and commendations in recognition of her outstanding service.
2) Hussein informed her on August 25, 2004 that along with several of her fellow flight attendants, she was being transferred from Manila to Jeddah starting the first week of September 2004 due to “operational requirements.”
3) Upon arriving in Jeddah on September 2, 2004, she discovered that many of the Jeddah-based flight attendants aged 40 and above had already submitted their resignation letters.
4) She was instructed to report to the office of the base manager on September 6, 2004, where she was informed that her employment contract with Saudia would not be renewed.
5) She was asked to sign a document acknowledging that she had been informed that her employment contract would expire in 30 days.
6) She was pressured to sign a pro forma resignation letter drafted by Saudia to avoid the humiliation of her abrupt termination.
• Saudia declaimed against the allegations of Castells and Centi-Mandanas (respondents) and contended that their resignation letters and exit interview forms, along with that of Bilbao, stated expressions of gratitude for the opportunity to work as flight attendants.
2. SC Decision / Resolution
• [A] careful scrutiny of the facts on record reveals-that contrary to the CA’s conclusion, Saudia was able to establish respondents’ voluntary resignation.
• First, Saudia effectively demonstrated that respondents’ resignation letters reflected the voluntary nature of their separation from the company, and were not prompted by any form of deceptive tactics or coercion on Saudia’s part. In actual fact, the resignation letters not only revealed an absence of reluctance or tension on respondents’ part but also conveyed genuine gratitude. There is no indication of hostility toward Saudia. The pronouncement of the Court in Bilbao v. Saudi Arabian Airlines, which arose from the same set of facts as the present case, is directly applicable and highly relevant to the issue at hand—
After a review of the case, we uphold the findings of the CA that Bilbao voluntarily resigned from her employment with Saudia. Her resignation letter and undertaking that evidenced her receipt of separation pay, when taken together with her educational attainment and the circumstances surrounding the filing of the complaint for illegal dismissal, comprise substantial proof of Bilbao’s voluntary resignation.
. . . .
In the instant case, Bilbao tendered her resignation letter a week after her transfer to the Jeddah office. In the said letter, Bilbao expressed her gratitude for the support which Saudia had given her for her eighteen years of service. Clearly, her use of words of appreciation and gratitude negates the notion that she was forced and coerced to resign. Besides, the resignation letter was hand-written by Bilbao on a Saudia form and was in English, a language she is conversant in. (Emphasis supplied)
• Second, respondents accepted the monetary benefits provided by Saudia and in return, they executed an undertaking, thereby settling and waiving any further claims or causes of action against Saudia. The Court has consistently held that a waiver or quitclaim is a valid and binding agreement between the parties, provided that it represents a fair and reasonable settlement, and that the person executing it does so voluntarily and with a full understanding of its implications.
• Lastly, respondents’ contention that they were coerced into signing the resignation letter, quitclaims, and waivers remains unsubstantiated and, therefore, lacks merit. Once again, Bilbao elucidates—
Even assuming that Saudia prepared the form in which Bilbao wrote her resignation letter as claimed, this Court is not convinced that she was coerced and intimidated into signing it. Bilbao is no ordinary employee who may not be able to completely comprehend and realize the consequences of her acts. She is an educated individual. It is highly improbable that with her long years in the profession and her educational attainment, she could be tricked and forced into doing something she does not intend to do. Under these circumstances, it can hardly be said that Bilbao was coerced into resigning from Saudia. (Emphasis supplied)
• Moreover, even if respondents genuinely believed that it was widely known among Saudi employees that when flight attendants of other nationalities were transferred to Jeddah due to ‘operational requirements,’ they were effectively coerced into resigning, this belief alone amounts to mere speculation or conjecture, and is insufficient to support the claim of constructive dismissal. After all, he who asserts, not he who denies, must prove. In the absence of concrete evidence, the Court must rely on the actual proof presented—the resignation letters, quitclaims, and waivers bearing the respondents’ signatures, which unequivocally demonstrate their intent to voluntarily terminate their employment with Saudia, rather than the unsubstantiated claim of coercion.
