Facts:

The case involves Regina S. Biboso, Nenita B. Biso, Fe Cubin, Magelende H. Demegillo, Emerita O. Panaligan, Nilda P. Tayo, Nelda Tormon, Arde M. Valenciano, Ma. Linda E. Villa, and the Vicmico Supervisory Employees Association (VICSEA) as petitioners against Victorias Milling Company, Inc. and the Office of the President of the Philippines as respondents. The events leading to the case began when the petitioners, who were employed as academic teachers at the St. Mary Mazzarello School operated by Victorias Milling Company, were notified on April 14, 1973, that they would not be rehired for the 1973-74 school year. The company filed a report with the Department of Labor on May 28, 1973, indicating that the petitioners' services would be terminated after June 30, 1973. The petitioners initially found success with the National Labor Relations Commission and the Secretary of Labor, but the private respondent appealed to the Office of the President. The Presidential Executive ...

Facts:

1. Employment Context:

   • Petitioners were employed as academic teachers at St. Mary Mazzarello School, operated by private respondent Victorias Milling Company, Inc. (VICMICO).
   • Their employment was on a probationary basis, with contracts renewed yearly.

2. Termination of Employment:

   • On April 14, 1973, petitioners were notified by the school Directress that they would not be rehired for the school year 1973-74.
   • A report of termination was filed with the Department of Labor on May 28, 1973, stating that their services would end on June 30, 1973.

3. Legal Proceedings:

   • Petitioners filed a complaint for reinstatement, which was initially successful before the Arbitrator, the National Labor Relations Commission, and the Secretary of Labor.
   • VICMICO appealed to the Office of the President, which reversed the decision, ruling that petitioners were not entitled to security of tenure as their employment was probationary and temporary.

4. Contracts and Probationary Status:

   • Petitioners signed contracts stating their employment was "temporary as and when required until June 30" of the respective school year.
   • The Office of the President noted that the Labor Code recognizes a maximum probationary period of three years for teachers, as per the Bureau of Private Schools' policy.

5. Allegation of Unfair Labor Practice:

   • Petitioners claimed their termination was due to their membership in the Vicmico Supervisory Employees Association (VICSEA).
   • The Office of the President found this allegation untenable, noting that other teachers in VICMICO-operated schools were union members without reprisals.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Probationary Employment and Security of Tenure:

   • Probationary employees are not entitled to security of tenure beyond the terms of their contracts.
   • The Labor Code allows for probationary employment, and the termination of such employment is valid if it complies with the contract terms and statutory regulations.

2. Unfair Labor Practice:

   • To constitute unfair labor practice, there must be clear evidence that the termination was motivated by anti-union animus.
   • In this case, the petitioners failed to prove that their union membership was the reason for their termination.

3. Discretion of the Office of the President:

   • The Court emphasized that the certiorari jurisdiction of the Supreme Court is limited to cases of grave abuse of discretion.
   • The Office of the President's decision was based on a thorough evaluation of the evidence and was not arbitrary or capricious.