Title
Brazil vs. STI Education Service Group, Inc.
Case
G.R. No. 233314
Decision Date
Nov 21, 2018
Faculty members claimed regular status but were deemed part-time under the 2008 MORPHE due to lacking master’s degrees; SC ruled no illegal dismissal, denying monetary claims.
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Case Digest (G.R. No. 233314)

Facts:

Employment Background

  • Petitioners Luningning Z. Brazil, Salvacion L. Garcera, and Rita S. De Mesa were faculty members of STI Education Services Group, Inc. (STI), a proprietary higher educational institution in the Philippines.
  • Brazil was first employed in 1997 as a part-time faculty member, while Garcera and De Mesa were hired in 2000 and 2001, respectively, also as part-time faculty members.
  • Brazil claimed she was regularized in 2004, Garcera in 2004, and De Mesa in 2009, based on their employment contracts and benefits received.

Allegations of Constructive Dismissal

  • In June 2011, petitioners were offered new contracts for the academic year 2011-2012. Brazil and De Mesa were offered part-time faculty positions, while Garcera was offered a probationary faculty position.
  • Petitioners refused to sign the contracts, arguing that their security of tenure as regular employees was being undermined.
  • They were informed that their 201 files lacked appointment papers and that they did not meet the qualifications under the 2008 Manual of Regulations for Private Higher Education (MORPHE), which requires a master’s degree for regular faculty status.
  • Petitioners countered that Garcera had completed her master’s degree, while Brazil and De Mesa were in the process of completing theirs.

Termination and Complaints

  • Petitioners were replaced by newly hired faculty members and were not given teaching loads for the new school year.
  • They filed complaints for illegal constructive dismissal, non-payment of salaries, separation pay, and other monetary claims before the National Labor Relations Commission (NLRC).

Respondents’ Defense

  • Respondents argued that petitioners were part-time faculty members under the 2008 MORPHE and could not attain regular status due to their lack of a master’s degree.
  • They cited a CHED advisory opinion stating that granting regular status to unqualified faculty members violates the MORPHE.
  • Respondents claimed that petitioners’ refusal to sign the new contracts led to the expiration of their previous contracts, and thus, there was no illegal dismissal.

Issue:

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Ruling:

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Ratio:

  1. Regular Employment Status: Under the 2008 MORPHE, only faculty members with a master’s degree can attain regular or probationary status. Petitioners, lacking the required qualifications, were part-time faculty members and could not be considered regular employees.
  2. Retroactive Application of MORPHE: The 2008 MORPHE applies to petitioners’ employment status, and their prior employment contracts did not override the MORPHE’s requirements.
  3. No Illegal Dismissal: Petitioners’ refusal to sign new contracts led to the expiration of their previous contracts. Since they were part-time faculty members, their employment was fixed-term, and non-renewal of contracts does not constitute illegal dismissal.
  4. Monetary Claims: Petitioners are not entitled to monetary claims as their employment was lawfully terminated under the MORPHE. The Court emphasized that equity and estoppel cannot contravene clear provisions of the law.


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