Case Digest (G.R. No. L-48494) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Brent School, Inc. and Rev. Gabriel Dimache v. Ronaldo Zamora and Doroteo R. Alegre (G.R. No. L-48494, February 5, 1990), petitioners Brent School, Inc. and its president Rev. Gabriel Dimache entered into a written contract on July 18, 1971 engaging respondent Doroteo R. Alegre as Athletic Director for a fixed five-year term at an annual salary of ₱20,000. Subsequent agreements dated March 15, 1973; August 28, 1973; and September 14, 1974 reaffirmed the same expiration date of July 17, 1976. On April 20, 1976, Brent School notified the Department of Labor of the intended termination upon “completion of contract, expiration of the definite period of employment,” and on May 26, 1976 Alegre accepted ₱3,177.71 in full settlement of services through July 17, 1976. Alegre then protested to a Labor Conciliator, claiming that after five years he had acquired regular employee status and could be dismissed only for just cause under the Labor Code (P.D. 442, as amended). The Regional Di Case Digest (G.R. No. L-48494) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment Contract
- On July 18, 1971, Brent School, Inc., through Rev. Gabriel Dimache, hired Doroteo R. Alegre as athletic director for a fixed term of five years (July 18, 1971 to July 17, 1976) at an annual salary of ₱20,000.
- Subsequent subsidiary agreements (March 15, 1973; August 28, 1973; September 14, 1974) reaffirmed the same duration and conditions.
- Termination Proceedings
- On April 20, 1976, Brent School filed a report with the Department of Labor notifying Alegre's services would end on July 16, 1976 due to “completion of contract.” On May 26, 1976, Alegre accepted ₱3,177.71 covering May 16 to July 17, 1976.
- Alegre protested before a Labor Conciliator, contending that after five years performing duties “usually necessary or desirable,” he had acquired security of tenure and could not be dismissed without just cause.
- The Regional Director treated Brent School’s submission as an application for clearance to terminate, denied it, and ordered Alegre’s reinstatement as a “permanent employee” with back wages. The Secretary of Labor and the Presidential Assistant for Legal Affairs affirmed these decisions.
- Petition for Certiorari
- Brent School filed a petition under Rule 65 seeking reversal of the President’s ruling—arguing no appeal procedure existed under PD 442—and challenging the prohibition of fixed‐term employment.
- The core issue was whether the amended Labor Code proscribes fixed‐period contracts and whether contract expiration is a valid ground for termination.
Issues:
- Are fixed‐period employment contracts valid under the Labor Code (PD 442, as amended by PD 850 and BP 130)?
- Does expiration of an agreed term constitute lawful termination without need for just cause, notice, or administrative clearance?
- Are all fixed‐term stipulations contrary to public policy, or only those intended to circumvent security of tenure?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)