G.R. No. 202761 - MRM Asset Holdings 2, Inc. vs. Standard Chartered Bank

Colegio de San Juan de Letran, a religious educational institution operated by the Order of Preachers, is the petitioner.
Isidra Dela Rosa-Meris is the respondent who was first hired in January 1971 as a probationary trial teacher, eventually attaining the rank of Master Teacher in June 1982 before resigning in March 1991.
The respondent was re-employed seven years later as a Junior Teacher C (February–April 1998) and, on October 21, 1999, was hired as a substitute teacher until her termination on October 3, 2003.

The controversy began on September 10, 2003, when several parents of preparatory pupils complained about the respondent’s alleged indifference and unprofessionalism in addressing their concerns.
The complainants also questioned the computation of the general average of their children, suspecting discrepancies in the grading system.
An investigation by petitioner revealed discrepancies between the “Dirty Record Book” and the “Clean Record Book” of the respondent, including altered grades, erasures without proper initials, and irregular entries that favored certain students.

On September 12, 2003, petitioner sent a letter to the respondent detailing the parents’ complaints and the discovered discrepancies in the records, demanding an explanation within 72 hours to avoid disciplinary action.
The respondent refused to acknowledge or personally receive the letter, prompting petitioner to resend the same via registered mail and LBC Express; receipt was confirmed on September 23, 2003.
The respondent alleged that she requested a written complaint from the principal but claimed not to have received any such documentation.

On October 2, 2003, the respondent was summoned for a conference with Rev. Fr. Edwin A. Lao, during which she was bluntly questioned about the alterations in the grading records.
Despite being advised to provide a written explanation for the discrepancies, the respondent refused to do so.
Following the conference, Fr. Lao terminated the respondent’s employment effective October 3, 2003, citing her conduct and the tampering with official school records.

The respondent instituted a complaint for illegal dismissal and damages before the Labor Arbiter (LA) on October 6, 2003.
The LA, in its decision dated May 14, 2004, found that the respondent had tampered with the class records and ruled her dismissal as valid, noting that the discrepancies were demonstrable from the comparison of the Dirty and Clean Records.
The National Labor Relations Commission (NLRC) initially modified the relief by awarding separation benefits in lieu of reinstatement but later, on November 18, 2005, reversed its stance, holding that the respondent’s misconduct warranted dismissal.
The Court of Appeals (CA) eventually rendered a decision on January 29, 2007, finding in favor of the respondent by ordering her reinstatement with backwages and separation pay, further modified on May 25, 2007 by granting attorney’s fees and interest in her favor.
Petitioner then filed a Petition for Certiorari with the Supreme Court seeking to review and reverse the CA’s decision.

Petitioner argued that the CA deviated from the established and accepted judicial procedures by altering factual findings established by the LA and NLRC, particularly on matters that required a direct visual comparison of records.
It was contended that the CA erred both procedurally and substantively, including in its awarding of attorney’s fees and interest on legal grounds not supported by the applicable laws.
Central to the petitioner’s argument was that the NLRC’s dismissal of the respondent’s appeal—including the failure to attach the mandatory certification of non-forum shopping—had already rendered the LA’s decision final and binding.

Whether the CA erred in reversing the NLRC’s dismissal of the respondent’s appeal on the ground that she failed to attach a certification of non-forum shopping to her memorandum of appeal.
Whether strict adherence to the non-forum shopping rule should be relaxed in cases involving the employment and substantial rights of teachers, or whether the rule must be applied in its literal sense even if it affects the outcome on the merits.

Whether the respondent’s unauthorized alterations, erasures, and tampering with the official school records—after their initial verification by subject coordinators—constituted serious misconduct justifying her dismissal.
Whether petitioner complied with the due process requirements in terminating the respondent, including the proper notice and opportunity to be heard.
Whether the CA improperly substituted its own findings in place of those of the Labor Arbiter and NLRC despite the existing evidentiary record indicating record tampering by the respondent.