Case Digest (G.R. No. 227070)
Facts:
Adamson University Faculty and Employees Union, represented by its President, and Orestes Delos Reyes v. Adamson University, G.R. No. 227070, January 31, 2022, Supreme Court Third Division, Leonen, J., writing for the Court.Petitioner Orestes Delos Reyes was a long‑serving professor and assistant chairperson of the Social Sciences Department at Adamson University and president of the Adamson University Faculty and Employees Union (the Union). On September 5, 2014, the university received a complaint by Josephine Esplago on behalf of her 17‑year‑old daughter, Paula Mae Perlas, alleging that while both held a door, Delos Reyes exclaimed “anak ng puta” to Paula Mae, causing her emotional trauma and amounting to abuse of a minor under RA 7610 and a violation of the University Code of Conduct.
The university president created an Ad Hoc Investigating and Hearing Committee which issued a show‑cause memorandum on September 12, 2014 charging Delos Reyes with gross misconduct and unprofessional behavior. After extensions and Delos Reyes’ written explanation (filed on Union letterhead and including a counter‑complaint), a consolidated hearing was held on October 7, 2014. On October 24, 2014, Adamson issued a Notice of Dismissal; the university denied reconsideration, and subsequently published a paid statement clarifying the grounds for dismissal.
Delos Reyes filed a Notice of Strike but the parties agreed to voluntary arbitration. The Panel of Voluntary Arbitrators, in a May 12, 2015 Decision, found his dismissal valid for gross misconduct and unprofessional behavior, taking into account his utterance, refusal to apologize, filing of counter‑complaints, refusal to sign notices, and prior complaints showing a pattern of abrasive conduct. Delos Reyes sought review, which the Court of Appeals denied in an April 28, 2016 Decision (with denial of reconsideration in an August 17, 2016 Resolution), concluding he was amply afforded procedural due process and that his dismissal did not constitute unfair labor practice.
Delos Reyes filed a petition before the Supreme Court under Rule 45 questioning the factual findings and alleging procedural b...(Pro-only)
Issues:
- Was petitioner Orestes Delos Reyes validly dismissed from employment?
- Did petitioner’s dismissal constitute an unfair labor practice under the Labor...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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