G.R. No. 90010-11 - Cagayan Capitol College vs. National Labor Relations Commission

Case Digest (G.R. No. 90010-11)
Expanded Legal Reasoning Model

Facts:

Parties & Employment Background

Petitioners: Cagayan Capitol College.
Private Respondents:

Virgilio P. Villegas – Employed as a college instructor in the Nautical Science Department on a probationary basis.
Leonor S. Pagapong – Employed as a high school instructor on a probationary basis.

Employment Chronology and Contractual Details

Respondent Villegas:

Initially hired on a ten-month contract ending March 31, 1982.
Re-engaged on subsequent contracts:

June 1, 1982 to March 31, 1983.

ii. June 1, 1983 to March 31, 1984, with an extension through May 31, 1984 to cover the summer session as part of the same school year.

After the expiration of his last contract, he re-applied for employment but his application was denied due to complaints from students supported by investigation reports from superiors.

Respondent Pagapong:

Initially hired on a contractual basis starting June 15, 1981, ending March 31, 1982, as a probationary instructor in the High School Department.
Re-employed through subsequent contracts:

Renewal covering June 1, 1982 to March 31, 1983.

ii. Third contract from June 15, 1983 to March 31, 1984.

Upon applying for re-employment with an accompanying clearance, her application was rejected based on the recommendation of her immediate superiors who found her performance inefficient due to frequent absences.

Filing of Complaints and Nature of Claims

Both respondents filed complaints before the NLRC for illegal dismissal, asserting:

They were dismissed without valid grounds.
Their constitutional right to due process and security of tenure was denied.

They claimed reinstatement with:

Backwages.
Moral damages and attorney’s fees.
Additional claims for underpayment of salary, allowances, wage orders, and their share in tuition fee increases per Presidential Decree No. 451.

The cases were docketed as:

NLRC Case no. RAB-C-0513-84 (Villegas).
NLRC Case no. RAB-C-0560-84 (Pagapong).

The cases were heard jointly given the identical issues and facts.

NLRC Decisions and Subsequent Proceedings

First NLRC Decision (August 8, 1985):

Dismissed the complaints on the ground that the respondents were still within the three-year probationary period prescribed by the Ministry of Education, Culture and Sports.

Modified NLRC Decision (May 30, 1989):

Found that Villegas had rendered six consecutive regular semesters and Pagapong three consecutive years as full-time teachers.
Applied the Manual of Regulations for Private Schools (7th Edition, 1984), which states:

The six (6) consecutive regular semesters for tertiary instructors and three (3) consecutive years for high school teachers are the probationary limits.

ii. Full-time teachers who have rendered three consecutive years of satisfactory service shall be considered permanent.

Determined that once the probationary period is successfully completed, the non-renewal of employment is tantamount to illegal dismissal.
Ordered the reinstatement of the respondents with three years backwages along with attorney’s fees at 10% of the total award; the claims for moral and exemplary damages were dismissed.

Motion for Reconsideration:

Filed by petitioners but was denied in a resolution dated July 28, 1989.

Supreme Court Petition:

Petitioners assailed the NLRC decision for alleged grave abuse of discretion and error in interpreting the Manual of Regulations for Private Schools, the Labor Code, and other applicable laws.
A writ of preliminary injunction was also sought to restrain enforcement of the NLRC decision pending the resolution of the petition.
A temporary restraining order (TRO) was issued on October 4, 1989, and later made permanent.

Performance Evaluations and Internal Policies

The Faculty Manual provided by petitioners clearly outlined:

Duties of teachers.
Grounds for termination or non-appointment to permanent status.

Performance Aspect:

In Villegas’ case, persistent student complaints and investigation findings led to a conclusion of unsatisfactory performance.
In Pagapong’s case, repeated inefficiency and excessive absences were found.

The incident underscores that even though both respondents had served for the requisite period, the attainment of permanent status depended on the satisfaction of established performance standards.

Issues:

Whether the completion of three consecutive years (or the equivalent period in terms of consecutive regular semesters) automatically confers permanent employment status on probationary teachers.

Is the criterion of three consecutive years sufficient irrespective of performance evaluations?
Must satisfactory performance be established despite the completion of the required period?

Whether the non-renewal of the employment contracts on the grounds of deficient performance constitutes illegal dismissal.

Did the petitioner violate the constitutional right to due process and security of tenure?
Was the employer’s decision to deny renewal, based on performance evaluations, sufficiently substantiated?

Whether the NLRC committed reversible error in its modified decision that awarded reinstatement with backwages and attorney’s fees.

Was there an abuse of discretion in interpreting the Manual of Regulations for Private Schools, the Labor Code, and other applicable laws?
Does the evaluation process afford the educational institution complete discretion in determining satisfactory performance?

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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Case Digest (G.R. No. 90010-11) Core Legal Reasoning Model Expanded

Facts:

Case Digest (G.R. No. 90010-11) Expanded Legal Reasoning Model

Facts:

Issues:

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Doctrine:

Case Digest (G.R. No. 90010-11)
Core Legal Reasoning Model

Expanded

Case Digest (G.R. No. 90010-11)
Expanded Legal Reasoning Model