Constructive dismissal in the Philippines happens when an employee resigns not out of free will, but because working conditions become intolerable. This can take the form of sudden demotions, loss of key responsibilities, or persistent humiliation from management.
The recent case of Bartolome v. Toyota Quezon Avenue, Inc., G.R. No. 254465, April 03, 2024 highlights the devastating impact of a hostile work environment on an employee's well-being and career. The petitioner, a regular employee tasked with selling cars and products for a corporation, faced disciplinary actions for alleged habitual absence. However, things took a turn for the worse during a meeting with management, where the company's president publicly humiliated the petitioner for bringing his sibling as counsel.
The situation escalated further as the petitioner’s accounts were withdrawn and transferred to another employee without explanation. He was then reassigned to a new team, where his new supervisor questioned his intentions with a direct and unsettling question: “Ano plano mo, magreresign ka?” (What’s your plan, are you going to resign?). This series of events created a hostile work environment that made it impossible for the petitioner to continue in his role, ultimately forcing him to tender his resignation.
The petitioner subsequently filed a complaint for illegal/constructive dismissal and money claims with the National Labor Relations Commission (NLRC), seeking justice for the unfair treatment he endured.
When the case reached the Supreme Court, it held that acts of disdain and hostile behavior such as demotion, uttering insulting words, asking for resignation, and apathetic conduct toward an employee constitute constructive illegal dismissal whenever by reason thereof, one's employment becomes so unbearable he or she is left with no choice except to resign.
Constructive dismissal occurs when harsh working conditions force an employee to resign, going beyond typical workplace disagreements. While strong words can be exchanged in employer-employee interactions, a hostile work environment is created when an employer's words are unreasonable, lack justification, or aim to degrade the employee's dignity. The doctrine of constructive dismissal protects labor dignity by acknowledging that certain employer actions can make continued employment unbearable.
If you believe you have been a victim of constructive dismissal in the Philippines, do not let your rights go unprotected. Our legal team at Cunanan Law Office is ready to guide you through the process of asserting your claims and securing justice against your employer. Contact us today at inquiries@mpeclaw.com or (+63) 976 385 6705 to schedule a consultation and take the first step toward protecting your career and livelihood.