Case Digest (G.R. No. 169464)
Facts:
Roque D.A. Dator v. University of Santo Tomas, G.R. No. 169464, August 31, 2006, Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.Petitioner Roque D.A. Dator was hired by respondent University of Santo Tomas (UST) in June 1983 as Instructor I with a maximum teaching load of 24 units. In December 1995 he also accepted employment as Graft Investigation Officer II at the Office of the Ombudsman; he did not disclose this outside full‑time employment to UST, and respondents only discovered it in the first semester of School Year 2000–2001.
On June 16, 2000 UST informed Dator that his teaching load would be reduced to 12 hours per week pursuant to Section 5, Article III of the UST Faculty Code (which limits teaching load for faculty with full‑time outside employment). Petitioner sought reconsideration and was temporarily granted an additional three teaching hours for SY 2000–2001; a subsequent June 15, 2001 request for another three‑unit increase was denied by Rev. Fr. Rodel Aligan. Dator filed a Complaint‑Affidavit with the Grievance Committee; the committee dismissed it and Rector Rev. Fr. Tamerlane Lana denied his appeal.
On February 19, 2002 petitioner filed before the Labor Arbiter a complaint for illegal reduction of teaching load, illegal change of employment status, damages, unpaid benefits, attorney’s fees, and illegal constructive dismissal. He relied on provisions of the Collective Bargaining Agreement (CBA) (Article IV, Sections 3, 5, 6, 7) claiming entitlement as a tenured faculty member to his previous load. Respondents asserted the Faculty Code (Article III, Secs. 5 and 6) controlled and that petitioner had misrepresented his outside employment.
The Labor Arbiter ruled for respondents and dismissed petitioner’s complaint. On appeal, the National Labor Relations Commission (NLRC) reversed and ordered restoration of Dator’s full‑time status and backwages; its denial of respondents’ motion for reconsideration was affirmed. Respondents then filed a petition for certiorari with the Court of Appeals, which reversed the NLRC in an April 27, 2005 decision (CA‑G.R. SP No. 81378) and dismissed petitioner’s complaint for lack of merit; the CA denied petitioner’s motion for reconsideration on August 24, 2005.
Petit...(Subscriber-Only)
Issues:
- Was the reduction of petitioner’s teaching load from 24 units to 12 units justified under applicable rules (Faculty Code and CBA)?
- Was petitioner denied due process in the reduction and subsequent administrative...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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