Oscar Adorado Casiple v. Greyhounds Security & Investigation Agency

Summary

Security guard Oscar Casiple resigned from Greyhounds Security Agency citing hostility from management and subsequently filed for constructive dismissal. The Labor Arbiter dismissed the complaint, but the NLRC reversed and awarded substantial damages. The Court of Appeals reversed the NLRC, finding no constructive dismissal. The Supreme Court affirmed, holding that Casiple failed to prove his resignation was involuntary. The Court established that mere verbal reprimands, even harsh ones, do not constitute constructive dismissal when based on legitimate performance issues. The decision reinforced that employees claiming constructive dismissal must prove with clear, positive, and convincing evidence that their resignation was coerced, and that the employer's conduct must be so unbearable as to foreclose any choice except resignation. This case clarifies the high evidentiary standard required for constructive dismissal claims and the distinction between voluntary resignation and forced resignation in Philippine labor law.