G.R. No. L-46953 - Mayuga vs. Court of Appeals

Petitioner served as a full‐time professor at St. Paul’s College of Manila for 22 years.
In February 1998, she verbally accepted a tutorial and a summer teaching load.
Due to an urgent family request in the United States, she planned to depart abroad to assist her brother and sister-in-law with the care of their children.
Consequently, she decided to revise her teaching schedule for the summer of 1998.

On March 31, 1998, the petitioner mailed a letter to Sister Natividad De Jesus Ferraren (the college president and dean) proposing a change in her teaching schedule to facilitate her early departure scheduled for April 27, 1998.
A related letter dated April 25, 1998 – which included an apology for not seeking prior approval – was delivered belatedly on April 26, 1998 to Sister Ferraren.
The petitioner claimed that her department chairperson, Ms. Shirley Agatep, and the college registrar, Ms. Lilia B. Santos, had approved the schedule change; however, both later clarified in their written explanations that they only endorsed her request without possessing the authority to approve such changes.
Despite the college’s policy which requires approval solely from the president and dean for changes in class schedules or leave applications, the petitioner neither sought such approval nor mentioned her planned schedule change when signing her conformity to the fixed summer load.

In response to the irregularities, Sister Ferraren instructed Ms. Agatep and Ms. Santos to supply written explanations regarding the petitioner’s claim of approval.
On May 19, 1998, a show-cause memorandum was issued, charging the petitioner with several offenses including:

The memorandum warned of disciplinary action, including dismissal, should the petitioner fail to respond within five days.

At the commencement of the 1998-1999 school year on June 2, 1998, the petitioner was absent, prompting the hiring of a substitute teacher for her subjects while she remained on the payroll.
On June 10, 1998, the petitioner personally delivered her written compliance admitting the schedule change without the requisite approval and pleaded for the disciplinary proceedings to be set aside, expressing instead a desire for early retirement.
Sister Ferraren instructed the petitioner to reduce her retirement request in writing to facilitate the release of her computed unpaid salaries and benefits; however, the petitioner failed to submit the written request.
An administrative hearing was conducted:

Formal notices were sent on July 9, 1998 to the petitioner, Ms. Agatep, and Ms. Santos, with the hearing scheduled for July 17, 1998.
A day before the hearing, the petitioner verbally indicated her intention to attend, yet during the hearing she neither admitted her error nor formalized her decision for early retirement.
She excused herself due to alleged illness and requested a rescheduling, leaving the hearing committee to proceed in her absence after assuring her that she could respond to the minutes later.
On July 29, 1998, the petitioner’s counsel informed the college that his client no longer intended to attend further hearings and demanded reinstatement with full backwages and preservation of her seniority rights and benefits.

After proceeding with the evidence and arguments (including those of Ms. Agatep and Ms. Santos), the hearing committee found the petitioner guilty of the charges noted in the show-cause memorandum, recommending early retirement and the payment of her benefits.

On October 6, 1998, the petitioner filed a complaint for illegal dismissal and non-payment of salaries before the Labor Arbiter.
Labor Arbiter Romulo S. Protacio ruled in the petitioner’s favor on December 22, 1999.
The private respondents appealed, and on December 29, 2000, the NLRC reversed the Labor Arbiter’s decision.
The Court of Appeals (CA), in its decision on August 6, 2001, affirmed the NLRC finding, effectively upholding the early retirement and dismissing illegal dismissal claims.
The petitioner then elevated the case via a petition for certiorari under Rule 65, raising issues regarding alleged grave abuse of discretion by the CA.

Whether the Court of Appeals committed grave abuse of discretion by affirming the NLRC’s finding that the private respondents granted the petitioner an early retirement.

Whether the CA erred in affirming that the petitioner was not illegally dismissed, thereby denying her reinstatement with full backwages and the preservation of her seniority rights and other benefits.

Whether the CA committed grave abuse of discretion in holding that Sister Ferraren cannot be held personally liable for the petitioner’s claims.

Whether the CA committed grave abuse of discretion by not awarding moral and exemplary damages and attorney’s fees to the petitioner, in light of the circumstances surrounding the proceedings.