G.R. No. 230744 - Salvador vs. Commission on Elections

Geraldine Michelle B. Fallarme and Andrea Martinez-Gacos were hired by San Juan de Dios Educational Foundation, Inc. as full-time teaching staff effective School Year (SY) 2003–2004.
Both petitioners received memoranda indicating their hiring; however, the memoranda did not specify whether their employment was on a regular or probationary basis.
In addition to teaching, Fallarme was designated to perform administrative duties as personnel officer and as head of the Human Development Counseling Services.

Despite being employed since SY 2003–2004, both petitioners were only instructed on March 1, 2006, to sign a written employment contract.
The contract, titled “Appointment and Contract for Faculty on Probation,” was signed for the second semester of SY 2005–2006 (from November 4, 2005 to March 18, 2006), thereby designating both petitioners as probationary teachers for the first time.
After the expiration of the probationary period, the college informed the petitioners that their contracts would not be renewed for the first semester of SY 2006–2007, citing the school’s “administrative prerogative” as the basis.

Respondents, including the college and its authorized representatives, alleged that the petitioners committed several acts of misconduct:

Both petitioners sold computerized final examination sheets to students without obtaining prior approval, despite clear instructions from their subject area coordinator.
Fallarme additionally sold sociology textbooks to her students without securing the necessary authorization from the school.
Martinez-Gacos organized out-of-campus activities with students without the requisite consent and in violation of the school’s Student Handbook.

These actions were presented by respondents as evidence of unsatisfactory performance which justified the nonrenewal of the employment contracts.

The petitioners filed a complaint for illegal dismissal, seeking reinstatement, back wages, and damages.
The labor arbiter ruled in favor of the petitioners, considering them regular employees entitled to security of tenure, referencing the 1992 Manual of Regulations for Private Schools.
Upon appeal, the National Labor Relations Commission (NLRC) reversed the labor arbiter’s decision, finding that the petitioners did not render satisfactorily acceptable service. Nonetheless, due to a deficiency in the observance of due process, the NLRC awarded P20,000 indemnity to each petitioner.
The Court of Appeals (CA) affirmed the NLRC ruling, upholding the college’s exercise of its administrative prerogative concerning the determination of regularization and the subsequent nonrenewal of contracts.

Whether the petitioners were regular employees of San Juan de Dios Educational Foundation, Inc. from the commencement of their employment.
Whether the dismissal (effected through nonrenewal of their contracts) of the petitioners was for a valid cause pursuant to the applicable statutory and administrative standards.
Whether the proper procedural requirements for dismissal, particularly the two-notice rule mandated by due process, were observed by the respondent college when terminating the petitioners' employment.