Case Digest (G.R. No. 233314)
Facts:
This case involves Luningning Z. Brazil, Salvacion L. Garcera, and Rita S. De Mesa (hereinafter referred to as the "petitioners") as they filed a complaint against STI Education Services Group, Inc. and Monico V. Jacob (the “respondents”). The events leading up to this case began with the petitioners' employment at STI College-Legazpi, where Brazil commenced her role as a part-time faculty member on June 3, 1997. Garcera and De Mesa followed, starting in June 2000 and June 2001 respectively. Over the years, their employment progressed, with Brazil being regularized in 2004, Garcera also in 2004, and De Mesa claiming regular status by 2009 due to the receipt of monthly salaries, akin to those of regular employees.In mid-2011, the petitioners were handed separate job offers that reversed their employment statuses back to part-time and probationary classification, leading to their refusal to sign these contracts. They contended that their regular status had previously been establ
Case Digest (G.R. No. 233314)
Facts:
Petitioners Brazil, Garcera, and De Mesa, who had long rendered teaching services at STI Education Services Group, Inc. (STI) as part-time faculty members, claimed that they had already obtained, either expressly or impliedly, a regular status granted by STI. Brazil and Garcera had been recognized as regular employees since 2004 through administrative acts and correspondence, while De Mesa asserted that by June 2009 she enjoyed the benefits of a regular position as evidenced by her fixed monthly salary. In June 2011, STI, relying on the 2008 Manual of Regulations for Private Higher Education (MORPHE) and related CHED rules requiring a master's degree for full-time, regular status, issued new employment contracts: Brazil and De Mesa were offered part-time faculty contracts and Garcera a probationary contract. The petitioners refused to sign the new job offers, arguing that doing so would forfeit their long-enjoyed security of tenure. Subsequently, STI replaced them with newly hired faculty, and the petitioners filed complaints alleging illegal constructive dismissal, claiming that STI’s unilateral change in employment status effectively terminated their regular appointments.Issues:
- Whether the mere fact that STI had treated the petitioners as regular employees in previous years, by granting them benefits and a de facto regular status, is sufficient to sustain claims for illegal dismissal when, according to the statutory requirement (i.e. the 2008 MORPHE and the 1992 Manual of Regulations for Private Schools), they did not qualify for a full-time or permanent status due to failure to meet the master’s degree requirement.
- Whether the doctrine of estoppel or equitable considerations can override the clear statutory mandate that only faculty who meet all the prescribed qualifications may attain regular or permanent status.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)