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CANDIDO ALFARO V CA Case Digest

Candido Alfaro worked as a helper for Star Paper Corp. but was transferred to a more difficult work after taking sick leave. He alleged he was pressured to resign in exchange for 13th month pay and sick leave pay. Star Paper claimed Alfaro asked to resign due to illness. The labor arbiter, NLRC, and Court of Appeals all ruled Alfaro resigned voluntarily. The Supreme Court denied Alfaro's petition, finding the lower courts established his resignation as voluntary, as he negotiated resignation with separation pay due to his lingering illness. However, Star Paper did not comply and was ordered to pay Alfaro's separation pay.

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Kenneth James Carlo Hizon
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341 views2 pages

CANDIDO ALFARO V CA Case Digest

Candido Alfaro worked as a helper for Star Paper Corp. but was transferred to a more difficult work after taking sick leave. He alleged he was pressured to resign in exchange for 13th month pay and sick leave pay. Star Paper claimed Alfaro asked to resign due to illness. The labor arbiter, NLRC, and Court of Appeals all ruled Alfaro resigned voluntarily. The Supreme Court denied Alfaro's petition, finding the lower courts established his resignation as voluntary, as he negotiated resignation with separation pay due to his lingering illness. However, Star Paper did not comply and was ordered to pay Alfaro's separation pay.

Uploaded by

Kenneth James Carlo Hizon
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© Attribution Non-Commercial (BY-NC)
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CANDIDO ALFARO v. COURT OF APPEALS, et al.

G.R. No. 140812, 28 August, 2001, THIRD DIVISION, (J. Panganiban)

Voluntary resignation is an act of an employee, who finds himself in a situation in which he


believes that personal reasons cannot be sacrificed in favor of the exigency of the service; thus, he
has no other choice but to disassociate himself from his employment. If the agreement was
voluntarily entered into and represented a reasonable settlement, it is binding on the parties and
may not later be disowned, simply because of a change of mind.

Petitioner Candido Alfaro (Alfaro) was employed as a helper/operator of private respondent


Star Paper Corp. (Star Paper). When Alfaro reported back to work after availing a sick leave, he was
surprised to find out that another worker was recruited to take his place. Consequently, he was
transferred to the wrapping section of Star Paper. Subsequently, he was assigned to a new work
which was even more difficult.

One day, Alfaro alleged that he was pressured to sign a resignation letter, and a “Release and
Quit Claim” in exchange for P3,000 as his 13 th month pay and 15 days sick leave pay. After a few
months, he filed a complaint to the Labor Arbiter (LA) for non-payment of separation pay and
complaint for illegal dismissal. Contrastingly, Star Paper contends that, because of his illness, it was
Alfaro who asked the company to allow him to resign. The LA, National Labor Relations
Commission (NLRC) and the Court of Appeals (CA) all ruled that Alfaro did resign voluntarily.

ISSUE:
Whether or not Alfaro was illegally dismissed (he did not resign voluntarily)

HELD:
Petition DENIED.

The factual findings of the LA, NLRC, as affirmed by CA, reveal that Alfaro resigned from
his work due to his illness, with the understanding that Star Paper would give him a separation pay—
which unfortunately, Star Paper did not comply with. The claim of Alfaro that he was illegally
dismissed cannot be sustained, considering that his voluntary resignation has been indubitably
established as a fact by the three tribunals.
.
Voluntary resignation is defined as an act of an employee, who finds himself in a situation in
which he believes that personal reasons cannot be sacrificed in favor of the exigency of the service;
thus, he has no other choice but to disassociate himself from his employment. Based on the facts, it
was Alfaro who negotiated for a resignation with separation pay as the manner in which his
employment relations with Star Paper would end. Alfaro was already suffering from a lingering
illness at the time he tendered his resignation. Alfaro’s continued employment would have been
detrimental not only to his health, but also to his performance as an employee of Star Paper. Alfaro’s
resignation with separation pay was the best option for him under the said circumstances.

The Court adds further that not all waivers and quitclaims are invalid as against public policy.
If the agreement was voluntarily entered into and represented a reasonable settlement, it is binding on
the parties and may not later be disowned, simply because of a change of mind. Moreover, an
employee who resigns and executes a quitclaim in favor of the employer is generally estopped from
filing any further money claims against the employer arising from the employment. Considering,
however, that Star Paper did not comply with its agreement with Alfaro, the Court ordered Star Paper
to pay Alfaro his separation pay amounting to P8,452.50.
**Guys, parephrase na lang if you want to pass this as part of your digests. Thanks! God Bless! Happy weekend!

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