Title
Aklan College, Inc. vs. Enero
Case
G.R. No. 178309
Decision Date
Jan 27, 2009
Teachers dismissed for allegedly instigating student protests; courts upheld dismissal but awarded unpaid benefits, affirming factual findings and correcting computations for fairness.
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Case Digest (G.R. No. 178309)

Facts:

Parties Involved:

  • Petitioner: Aklan College, Inc. (now Aklan Catholic College), an educational institution in Kalibo, Aklan.
  • Respondents: Perpetuo Enero, Arlyn Castigador, Nuena Sermon, and Jocelyn Zolina, high school teachers employed by the petitioner.

Background:

  • On November 15, 16, and 17, 1994, and January 6, 10, and 11, 1995, high school students of Aklan College held mass actions (demonstrations) against the high school principal at a public plaza opposite the school. The demonstrations were conducted with valid permits from the Office of the Mayor.
  • Petitioner alleged that the protests were illegal strikes instigated by the respondents, not purely student demonstrations. An administrative investigation was conducted, and respondents were dismissed for causes under Articles 264 and 282 of the Labor Code, Section 16 of the Education Act of 1982, and paragraphs (d) and (e) of Section 94 of the Manual of Regulations for Private Schools.

Labor Arbiter (LA) Decision:

  • Respondents filed a case for illegal dismissal. The LA ruled in their favor, stating there was no evidence they abandoned their classes. The LA held that their participation in the rallies was passive and protected by their constitutional right to freedom of expression. The LA ordered their reinstatement and awarded backwages, 13th month pay, service incentive leave pay, moral damages, and exemplary damages.

NLRC Decision:

  • The National Labor Relations Commission (NLRC) reversed the LA’s decision, finding that respondents instigated the students to rally due to personal grievances against the principal. The NLRC declared the dismissal valid but ordered the payment of 13th month pay and service incentive leave pay.

Court of Appeals (CA) Decision:

  • The CA affirmed the NLRC’s decision but modified the computation of 13th month pay and service incentive leave pay based on the respondents’ employment history. The CA denied petitioner’s motion for reconsideration.

Issue:

  1. Whether the Court of Appeals erred in affirming the NLRC’s decision ordering the petitioner to pay respondents 13th month pay and service incentive leave (SIL) pay.
  2. Whether the Court of Appeals erred in increasing the monetary awards of 13th month pay and SIL pay in favor of the non-appealing respondents.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court upheld the CA’s decision, affirming the award of 13th month pay and service incentive leave pay to the respondents. The Court emphasized that factual findings of lower courts are binding and that the CA’s modification of the monetary awards was necessary to ensure justice.


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