Facts:

The case involves Vanessa Laura Arcilla, the petitioner, and San Sebastian College-Recoletos, Manila, the respondent. Arcilla, a qualified academic with a master’s degree in counseling psychology and certifications as a guidance counselor and psychometrician, was appointed as a full-time probationary faculty member in the College of Arts and Sciences for the Psychology department on December 17, 2014. The terms of her appointment declared that her employment commenced on November 21, 2014, and would conclude on March 31, 2015, unless extended at the discretion of San Sebastian College, which maintained the right to revoke her appointment if she violated the employment contract or engaged in acts contrary to the institution's interests or moral values. Although no classes were assigned to her during the summer semester, she was reappointed on April 24, 2015, for another fixed term, running from June 1, 2015, to October 31, 2015, with the same terms as the prior contract.

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Facts:

Parties and Background

• Vanessa Laura Arcilla, a master's degree holder in counseling psychology and a registered guidance counselor and psychometrician, is the petitioner.
• San Sebastian College-Recoletos, Manila—a private educational institution operated by the Augustinian Recollect Fathers and duly recognized by the Commission on Higher Education—is the respondent.

Appointment and Employment Terms

• On December 17, 2014, Arcilla was appointed as a full-time probationary faculty member of the College of Arts and Sciences’ Area of Psychology for the second semester of School Year 2014–2015.
• Her appointment commenced on November 21, 2014 and was set to end on March 31, 2015, subject to extension or renewal at the discretion of the College.
• The employment contract included a provision that the contract could be revoked before the expiration period if Arcilla violated the employment terms or acted against the school’s interests, students, or moral values.
• For the subsequent semester:
• Although no classes were assigned during the summer semester, Arcilla was reappointed on April 24, 2015 for the first semester of School Year 2015–2016.
• Her new fixed‐term contract (from June 1, 2015 until October 31, 2015) maintained the same terms and conditions, effectively overlapping with her probationary status.
• Non-Renewal and Notice of Termination
• On October 9, 2015, the college dean informed Arcilla that she would not be given a teaching load, citing a low enrollment as the reason.
• In a letter dated October 21, 2015, Arcilla was advised that her probationary contract would not be renewed.

Initiation of Legal Proceedings

• On February 2, 2016, Arcilla filed a Complaint before the National Labor Relations Commission (NLRC) for illegal dismissal, alleging that she was terminated without a just or authorized cause.
• Conciliation-mediation conferences resulted in the partial settlement of some claims (13th month pay and over-deductions), with the remaining issues referred to the Labor Arbiter.
• In the Labor Arbiter’s Decision dated July 28, 2016, it was determined that her employment had merely expired and that no illegal dismissal occurred.
• The NLRC, in its November 15, 2016 Decision, reversed the Labor Arbiter’s finding and declared that Arcilla had been illegally dismissed, thereby awarding her backwages, separation pay, and attorney’s fees.
• Following the NLRC’s ruling, the Court of Appeals reversed the NLRC Decision on November 29, 2017 by reinstating the Labor Arbiter’s decision, holding that her employment was purely probationary and that termination upon expiration of the fixed term was valid under the prevailing rules.

Procedural and Substantive Issues Raised in the Petition for Review

• On December 21, 2017, Arcilla filed a Petition for Review on Certiorari before the Supreme Court, challenging:
• The proper procedural mode of filing such a petition in lieu of a motion for reconsideration.
• The validity of the timing of respondent’s Petition for Certiorari before the Court of Appeals.
• The substance of the decision that her dismissal was lawful.
• Arcilla contended that when a probationary status overlaps with a fixed-term contract (used purely as a convenient arrangement in line with the academic calendar), the probationary provisions of the Labor Code must prevail.
• She further argued that her employment could be terminated only for a just cause or for failing to meet clearly communicated reasonable standards, none of which were evidenced in her case.
• Respondent maintained that the termination was valid since her employment was on a probationary basis and did not achieve permanent status.

Issue:

Whether the Court of Appeals erred in finding that the National Labor Relations Commission (NLRC) gravely abused its discretion in declaring Arcilla’s dismissal illegal.

• Is the application of probationary employment provisions, despite the fixed-term nature of the contracts, the correct approach under the law?
• Did the CA properly limit its review to questions of law as prescribed under Rule 45 of the Rules of Court?

Whether the mere expiration of a fixed-term contract, when overlapping with probationary employment, constitutes a lawful termination.

• Must an employer still invoke the need for a just or authorized cause, or the failure to meet established standards, even when fixed-term contracts are used?

Whether the employer’s use of fixed-term contracts purely for calendar convenience circumvents the protections afforded to probationary employees under the Labor Code.

• Does the employment arrangement—where the contract term overlaps with the probationary period—mandate that the probationary character prevail in termination considerations?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)