Title
De La Salle University vs. Lao
Case
G.R. No. 56566
Decision Date
Apr 15, 1985
Lolita Lao, a probationary professor at DLSU, contested her termination after her one-year probation. The Supreme Court ruled her termination valid, as her permanent contract was unsigned and withdrawn, dismissing her damages claim.

Case Digest (G.R. No. L-9396)
Expanded Legal Reasoning Model

Facts:

  • Parties and Nature of the Case
    • Petitioner: De La Salle University, represented by its officials – Brother Daniel Ortiz, FSC and Dean Patricio Ceballos.
    • Respondent: Lolita U. Lao, former assistant professor, and by extension, issues involving the Court of Appeals.
    • Core Issue: The alleged wrongful or “malicious” dismissal of Lao upon the completion of her one-year probationary period as an assistant professor.
  • Appointment and Employment Details
    • Appointment as a Probationary Employee
      • Lao was hired as a “non-tenured full-time probationary assistant professor C” with an annual salary of P13,000, as evidenced by a memorandum dated October 22, 1974 from the chairman of the Economics Department addressed to the academic vice-president.
      • The memorandum emphasized that Lao was hired full-time effective October 16, 1974 to strengthen the Economics Department.
    • Contractual Arrangements
      • In June 1975, Lao received a contract by the department secretary for the 1975-76 school year, stipulating her employment as a full-time faculty member at P15,155 per annum.
      • Lao duly signed the contract, providing her residence certificate number, place, and date of issue; however, the university president did not sign the contract because it was not forwarded to him by Frank Tajanan, the chairman of the Economics Department.
  • Performance and Termination Process
    • Work and Duration of Employment
      • Lao assumed her position and performed academic duties during the first semester of the academic year 1975-76.
      • The employment relationship was primarily governed by her status as a probationary employee.
    • Notice of Termination
      • In August 1975, Lao inquired about the status of her contract.
      • Frank Tajanan informed her of the intent to terminate her services effective at the end of the first semester (which coincided with the expiration of her one-year probationary period).
    • Confirmation of Termination
      • Dean Patricio R. Ceballos confirmed via a letter dated August 29, 1975 that Lao’s probationary period would end after the first semester and that the university opted against offering her permanent employment.
      • Brother Daniel Ortiz, acting dean, reinforced the termination by confirming in his letter dated September 30, 1975 that her services would be terminated on October 15, 1975.
    • Lao’s Reaction and Legal Action
      • Lao protested the abortive contract and terminated employment (as indicated by exhibits and records presented in the case file).
      • On October 3, 1975, she filed a petition seeking to restrain the university and its officials from terminating her services on October 15, 1975 and demanding damages in the amount of P99,000.
      • Subsequent developments saw her filing an amended petition on January 7, 1976, limiting her relief solely to the recovery of damages.
  • Procedural History and Court Decisions
    • Lower Court Ruling
      • The lower court found that the university and its officials had violated Lao’s rights under the full-time contract by unlawfully terminating her probationary employment.
      • The court awarded Lao P90,000 in moral and exemplary damages, along with attorney’s fees, holding the officials solidarily liable based on provisions of the Civil Code (articles 1701, 20, 21, 2208(11), 2219(10), 2229 and 2232).
    • Appellate Court Decision
      • The Court of Appeals affirmed the lower court decision on November 12, 1980.
    • Issue on Jurisdiction
      • Appellants (the university and its officials) argued that the case was within the exclusive jurisdiction of the National Labor Relations Commission (NLRC) or Labor Arbitrators under the Labor Code, specifically referencing article 265(f) (later article 217(5)).
      • The contention was that the existence of employer-employee relations is presumed under the relevant labor laws, raising the question of jurisdiction.
  • Contentions Raised on Appeal
    • Jurisdiction Issue
      • The appellants maintained that matters arising from employer-employee relations should be handled by the NLRC and not the civil courts.
    • Employment Status and Contract Validity
      • The appellants further contended that Lao had never attained permanent employee status since the contract for permanent employment was never completed (it was unsigned by the university president, legally withdrawn before its effectivity, and was never delivered to Lao).
      • Hence, Lao was only a probationary employee, and her termination was legally valid.

Issues:

  • Jurisdiction of the Court of First Instance vs. the NLRC
    • Whether the Court has proper jurisdiction over a claim for damages arising from issues of employment termination when the Labor Code confers exclusive jurisdiction on Labor Arbitrators and the NLRC for employer-employee relations.
  • Existence and Validity of the Employment Contract
    • Whether Lao had actually achieved permanent employment status under the contract, or whether she remained a probationary employee whose employment could legally be terminated by the university.
  • Cause of Action for Damages
    • Whether Lao is entitled to claim damages on the grounds that an enforceable contract for permanent employment existed and was wrongfully breached by the termination of her probationary employment.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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