Case Digest (G.R. No. 226358) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Claret School of Quezon City v. Madelyn I. Sinday (G.R. No. 226358, October 9, 2019), the petitioner, an educational institution in Quezon City, engaged respondent Sinday in April 2010 as a releasing clerk for its annual book sale. Over the next three years, she successively worked as a filing clerk in Human Resources, returned as a releasing clerk, then in July 2011 was appointed secretary at the newly opened Claretech department. Although a January 10, 2013 letter indicated her classification as a regular non-academic employee, the school in May 2013 had her sign a Probationary Employment Contract for six months. Upon its expiration, the school allegedly cited cost-cutting and administrative changes to terminate her services on July 31, 2013. Desperate, Sinday served as substitute teacher aide from August to October 2013, but was not rehired thereafter despite repeated pleas. She filed a complaint for illegal dismissal in February 2014. The Labor Arbiter ruled in her favor, Case Digest (G.R. No. 226358) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Relationships
- Petitioner Claret School of Quezon City (Claret) is a non-sectarian educational institution.
- Respondent Madelyn I. Sinday is the wife of a longtime Claret driver and mother of scholars at the school.
- Employment History of Sinday
- April 2010–July 2011: Engaged in successive short-term roles – releasing clerk for book sale, filing clerk in HR, then back as releasing clerk.
- July 15, 2011–July 31, 2013: Hired as secretary at Claret Technical-Vocational Training Center (Claretech), with alleged April 2013 classification as regular non-teaching employee. Claret later presented a Probationary Employment Contract (Jan 16–Jul 15, 2013).
- August 1–October 25, 2013: Worked as substitute teacher aide; ceased work upon return of permanent aide.
- Sinday repeatedly sought reinstatement in other capacities but was refused.
- Claims and Procedural History
- February 18, 2014: Sinday filed for illegal dismissal, alleging regular status due to continuous service in activities necessary to Claret’s business.
- Labor Arbiter (Sep 11, 2014): Found Sinday a regular employee; ordered reinstatement and backwages of ₱116,268.08 plus attorney’s fees.
- NLRC (Jan 14, 2015): Reversed; dismissed complaint, ruling Sinday was a part-time contractual employee duly informed of fixed terms.
- CA (Mar 30, 2016): Reversed NLRC; affirmed illegal dismissal; ordered backwages, separation pay in lieu of reinstatement, ECOLA, 13th-month pay, interest, and costs. Petition for review on certiorari filed by Claret before the Supreme Court.
Issues:
- Whether factual issues may be resolved in this Rule 45 petition.
- Whether Madelyn I. Sinday attained regular employment status.
- Whether Sinday was illegally dismissed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)