Supreme Court/File
Supreme Court/File

MANILA — The Supreme Court has dismissed the labor suits for illegal dismissal filed by two former flight attendants of Saudi Arabian Airlines, ruling that they voluntarily resigned and were not constructively dismissed.

In a 12-page decision penned by Associate Justice Japar Dimaampao, the Court’s Third Division reinstated the ruling of the National Labor Relations Commission (NLRC), which found that Maria Lourdes Castells and Shalimar Centi-Mandanas had freely tendered their resignations, negating their claims of constructive dismissal.

Castells and Centi-Mandanas were hired as flight attendants in 1986. In 2004, they received an inter-office memorandum from the airline’s head office directing their transfer from Manila to Jeddah due to operational requirements.

Both subsequently submitted resignation letters and executed quitclaims acknowledging receipt of their full end-of-service awards and final settlements, and that they had no further claims against the airline.

Nearly a year later, they filed complaints for illegal constructive dismissal, alleging they were forced to sign their resignation letters and quitclaims.

In her affidavit, Castells claimed it was common practice for flight attendants of other nationalities ordered transferred to Jeddah to be compelled to resign, adding that she was allegedly included in the transfer list because she was 39 years old.

Centi-Mandanas, for her part, said she was pressured to sign a pro forma resignation letter to avoid the humiliation of abrupt termination.

A labor arbiter initially ruled in favor of the two flight attendants, finding that they were constructively dismissed. The NLRC later reversed the ruling, holding that they failed to present substantial evidence to prove coercion.

The Court of Appeals reinstated the labor arbiter’s decision, saying it was unnatural for employees to voluntarily abandon a well-paying job held for nearly two decades without compelling reason. It also noted a pattern showing that flight attendants who resigned during that period were around 40 years old, suggesting age-based discrimination.

However, the Supreme Court sided with the NLRC and ruled that the resignations were voluntary.

The high court reiterated that constructive dismissal occurs when continued employment becomes impossible, unreasonable, or unlikely due to demotion or diminution of pay and benefits, while resignation is a voluntary act based on personal reasons.

In finding the resignations voluntary, the Court cited the absence of reluctance or hostility in the resignation letters, which conveyed gratitude to the employer, as well as the acceptance of monetary benefits and execution of quitclaims waiving further claims.

The Court also rejected the claim that it was widely known among Saudi Arabian Airlines employees that transfers to Jeddah effectively forced flight attendants to resign, saying such belief was mere speculation and insufficient to prove constructive dismissal.

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