G.R. No. 178008 - San Ferdo Regala Trading, Inc. vs. Cargill Philippines, Inc.

Seven individual private school teachers (including union members)
Represented by the Espirito Santo Parochial School Faculty Association and individual respondents

Employment and Contract Details
The seven respondents were hired on a probationary basis on June 1, 1984.
Their appointments were evidenced solely through appointment papers rather than formalized contracts specifying a fixed employment period.
Under the Bureau of Private Schools’ policy, probationary employment for teachers is extended to three years regardless of conflicting interpretations regarding a schoolyear-to-schoolyear arrangement.

Termination of Employment
Between April 1 and 15, 1985, the petitioner-school terminated the services of the seven respondents.
There was no clear evidence showing that the termination was for just cause or for failing to meet the requisite standards.
The termination was challenged as an illegal dismissal and charged as an act of unfair labor practice.

Legal Proceedings and Decisions Prior to the Court
On May 8, 1985, the respondents charged the school with unfair labor practices and illegal dismissal, also seeking damages.
The labor arbiter ruled:

Finding respondents guilty of unfair labor practice
Ordering the reinstatement of the respondents with full backwages from the start of the school year 1985-1986 until their reinstatement
Granting attorney’s fees equivalent to 10% of the total award
Dismissing the claim for damages due to insufficiency of evidence

On appeal to the National Labor Relations Commission, the labor arbiter's decision was affirmed on February 29, 1988, except that the charge on unfair labor practice was dismissed for lack of sufficient evidence.

The respondents were not dismissed but rather, their contracts merely expired naturally without renewal.
The employment contracts are structured on a schoolyear-to-schoolyear basis, thereby negating any claim of illegal dismissal.
Reference cases like Biboso v. Victorias Milling Company and Buiser v. Leogardo, which endorsed year-to-year contracts, are applicable to their situation.
The dismissal was not based on union membership since head teachers (also union leaders) recommended the termination.

Under the Manual of Regulations for Private Schools, the probationary period for teachers is three years, and dismissal during this period is only permissible for just cause.
Their termination in less than one year of service was therefore illegal.

There was no valid contract stipulating a schoolyear-to-schoolyear employment basis.
The dismissal was without just cause since the teachers' performance ratings ranged from 85% to 90%, clearly indicating satisfactory performance.

Validity of the Termination
Whether the termination of the probationary teachers was legally valid.
Whether the termination was effectuated for just cause or merely resulted from an alleged expiration of contracts.

Unfair Labor Practice
Whether the acts constituting the termination amounted to unfair labor practices under the law.
Whether the involvement of union leaders in the dismissal process negated or influenced the claim of unfair labor practice.

Compliance with Applicable Employment Provisions
Whether the petitioner-school complied with Article 282 (now Article 281) of the Labor Code concerning termination of probationary employees.
Whether the invocation of decisions like Biboso, which dealt with contracts specifying a definite period (year-to-year), is relevant to the current case involving appointment papers without a set termination period.

Appropriate Remedies
Whether the respondents are entitled to reinstatement and full backwages.
The extent of the requisite remedy, particularly the limitation of backwages to three years as determined by the court.