MOST OFTEN THAN NOT, even if the employee leaves because he wants to leave, he gets liquidation. It's just not worth the hassle going through the labor courts (labor lawyers cost money, you know...)
Even though "legally" such employee is not entitled to liquidation, he can be a PITA if not previously "agreed upon" liquidation when he goes. Usually this is done in writing prior to employee leaving. If the business owner does not want to accept that, the employee can become a real PITA then. He can be rude to customers, do FB all his day on his computer, etc...at the end, he will be FIRED (and that is what he wants) and then even if "legally" not entitled to liquidation if he does not do his job as he should and causes his employer a loss, it is known that courts will side with such fired employee anyway.
So going to the beginning of the story, it is always better to "make arrangements" and liquidate. Otherwise you may end up with a PITA employee who causes you huge reputation damage (just imagine such employee telling a customer that he is a stupid SOB)...or he is repairing something for a customer and makes a huge mess and f***d up work that is even worse off than in the beginning, etc....I mean, do you want THAT to happen in your business? It is a known fact, happy employees mean happy customers. An unhappy employee who wants to leave but the owner is not keen on liquidating him if he leaves, well..unhappy employee means unhappy customers.