G.R. No. L-47629 - Garcia vs. Martinez

Ms. Belo had been a full-time teacher at Chiang Kai Shek College (CKSC) since 1977.
In view of her family situation—specifically, her children being very young and lacking proper care—she applied for a leave of absence for the school year 1992–1993 on June 8, 1992.
The then-principal, Mrs. Joan Sy Cotio, approved her application, lending an initial appearance of procedural propriety.

On June 15, 1992, Ms. Belo received a letter (dated June 9, 1992) from Mr. Chien Yin Shao, the President of CKSC, which explained the school’s policy:

The school did not guarantee any teaching load upon an employee’s return from leave.
Only teachers currently in service were entitled to privileges such as free tuition for their children.

Despite the information, Ms. Belo took her leave of absence, which later had significant implications for her employment status.

While on leave, on July 8, 1992, Ms. Belo learned that one of her children had been sent out of the examination room for not having paid tuition fees—a circumstance directly tied to the school’s policy on free tuition.
This embarrassing incident compelled her to pay all school fees for her children, allegedly under protest.
Upon the expiration of her one-year leave in May 1993, Ms. Belo indicated her readiness to resume teaching and reported to Mrs. Cotio.
However, her reapplication was denied, and she was informed on July 21, 1993 (via a letter dated July 1, 1993 by Mr. Chien) that her confirmation was filed late and that the school had already assigned teaching loads to non-permanent teachers.

Ms. Belo filed a complaint with the Labor Arbitration Office claiming illegal dismissal along with non-payment of salaries, benefits, and damages.
The Labor Arbiter, in a decision of October 18, 1995, dismissed her complaint on the basis that there was no dismissal but merely the non-allocation of a teaching load due to the school’s policies and the timing of her reapplication.
On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision, holding that the school’s policies effectively amounted to constructive dismissal.
The NLRC directed the petitioners to reinstate Ms. Belo immediately with full back wages from the time of her dismissal, while dismissing her claims for moral, exemplary damages, and attorney’s fees due to insufficient evidence of bad faith.

The petitioners (CKSC and its president) filed a petition for certiorari with the Court of Appeals, arguing that the NLRC had gravely abused its discretion by:

Overturning the Labor Arbiter’s factual findings (even though Ms. Belo indicated she was appealing on a pure question of law).
Holding that Ms. Belo was constructively dismissed, contrary to evidence showing she was not illegally dismissed.
Awarding Ms. Belo monetary benefits unlawfully.

The Court of Appeals, however, held that the NLRC correctly identified that Ms. Belo was constructively (and illegally) dismissed on account of the school’s discriminatory policy implementations.
It further clarified that the inconsistencies in terminology (regarding whether the appeal was on a question of law or fact) did not infringe upon her right to security of tenure.

The letter of June 9, 1992, and subsequent written statements of policies (dated March 13, 1992, and March 12, 1993) detailed the conditions under which teachers could continue employment:

Teachers with satisfactory service and full-time status were generally considered permanent and were not required to reapply.
Probationary teachers were mandated to reapply, and failure to do so was taken as a lack of interest to continue teaching.
Notably, the policy on extending free tuition fees to children was modified for teachers not in service, which was applied to Ms. Belo upon her return from leave.

The Court found that these policies were applied in a discriminatory and retroactive manner which singled out Ms. Belo, effectively sidelining her from the teaching staff.

Whether the NLRC and subsequently the Court of Appeals correctly characterized Ms. Belo’s situation as a case of constructive (illegal) dismissal.

Is the policy of non-assurance of a teaching load for those on leave tantamount to a dismissal?
Did the retroactive application of modified benefits (free tuition for children) and the reapplication requirement constitute discrimination?

Whether the lower tribunals erred in delving into factual determinations despite Ms. Belo’s assertion that her appeal was a pure question of law.

Does a statement pertaining to a pure legal question preclude review of the factual findings allegedly favoring a different conclusion?

Whether the school’s implementation of its written and customary policies effectively deprived Ms. Belo of her security of tenure and due process rights.

Whether the conflicting decisions between the Labor Arbiter and the NLRC/CA justify the review and reversal of the former’s findings.