G.R. No. 200922 - People vs. Concepcion y Bulanio

Petitioner: Aklan College, Inc. (presently known as Aklan Catholic College), an educational institution located in Kalibo, Aklan.
Respondents: Four high school teachers—Perpetuo Enero, Arlyn Castigador, Nuena Sermon, and Jocelyn Zolina—who were employed by petitioner.

In November 15, 16, and 17, 1994, and January 6, 10, and 11, 1995, high school students organized mass actions (demonstrations) against the principal of the high school department.
The demonstrations took place at a public plaza opposite the school and were authorized by valid permits issued by the Office of the Mayor.
Petitioner contended that these rallies, though executed by students, were orchestrated by the respondents to function as an illegal strike rather than a simple student protest.

An administrative investigation was conducted during which the respondents were given an opportunity to explain their involvement.
Following the investigation, the respondents were dismissed for causes under Articles 264 and 282 of the Labor Code, Section 16 of the Education Act of 1982, and specific provisions of the Manual of Regulations for Private Schools (paragraphs (d) and (e) of Section 94).
The dismissed teachers filed a case for illegal dismissal before the Labor Arbiter (LA).

The LA rendered a decision on January 29, 1999, absolving the respondents and holding petitioner liable for illegal dismissal.
The LA’s ratiocination included the observation that respondents did not abandon their classes as they were passively allowing their students to rally, thus only exercising their right to freedom of expression.
The LA awarded backwages, 13th month pay, service incentive leave (SIL) pay, moral damages, and exemplary damages, with detailed computation of monetary awards for each respondent.

The National Labor Relations Commission (NLRC) subsequently reversed the LA’s decision, declaring that the dismissal of the respondents was valid.

The NLRC found that the mass action stemmed not from a labor dispute but from personal acrimony against the high school principal, accusing him of practices such as assigning ticket-selling quotas and deducting ticket costs from salaries.
The NLRC held that the respondents had improperly exploited their students to redress personal grievances, which was unbecoming of their professional status.
The NLRC awarded only the respondents’ unpaid 13th month pay and SIL pay, with detailed computations based on their employment histories.

A Separate Dissenting Opinion was rendered by Presiding Commissioner Irenea E. Ceniza, who maintained that the evidence did not support the view of high-handed machinations by the respondents.
Both parties filed motions for reconsideration, which were denied by the NLRC on February 27, 2004.
Petitioner then filed a petition for certiorari before the Court of Appeals (CA), challenging the NLRC decision—specifically, the award of 13th month pay and SIL pay—on the ground that the respondents were validly dismissed.
On October 27, 2006, the CA rendered its decision:

The CA held that the NLRC’s award was proper, finding that petitioner had not paid the mandatory benefits.
It modified the monetary computation to reflect each employee’s specific period of employment.
Petitioner’s subsequent motion for reconsideration filed on June 6, 2007, was denied.

Whether the award of 13th month pay and service incentive leave (SIL) pay to the respondents is proper, given that they were validly dismissed from employment.
Whether the Court of Appeals committed reversible error by:

Affirming the NLRC’s decision that awarded the respondents 13th month pay and SIL pay.
Increasing the monetary awards for 13th month pay and SIL pay in favor of the non-appealing respondents by modifying the computation to conform to their employment histories.