Case Digest (G.R. No. 96126)
Facts:
- Esteria F. Garciano was employed as a teacher at the Immaculate Concepcion Institute.
- In January 1982, she applied for an indefinite leave of absence to accompany her daughter to Austria.
- The leave was recommended by the school principal, Emerito Labajo, and approved by the Board President.
- On June 1, 1982, while Garciano was abroad, Labajo informed her husband of her termination due to the absence of a written contract and difficulty in finding a substitute teacher.
- Upon her return in late June 1982, Garciano received the termination letter.
- On July 7, 1982, the Board of Directors reinstated her effective July 5, 1982, declaring the termination null and void.
- Following her reinstatement, several Board members resigned due to faculty backlash.
- Garciano filed a complaint for damages against the respondents in September 1982, alleging discrimination and illegal dismissal.
- The trial court ruled in her favor in August 1985, awarding substantial damages.
- The Court of Appeals reversed this decision in August 1990, dismissing the complaint and absolving the respondents of liability.
- Garciano's motion for reconsideration was denied, leading her to file a petition for review.
Issue:
- (Unlock)
Ruling:
- The Supreme Court dismissed the petition for lack of merit, affirming the Court of Appeals' decision.
- The Court held that the private respondents were not liable for damages as they lacked the authority to te...(Unlock)
Ratio:
- The Supreme Court determined that the Board of Directors had exclusive authority to hire and fire teachers.
- The termination letter sent to Garciano lacked legal effect as it was not authorized by the Board.
- Garciano was aware of the Board's authority, and their reinstatement order nullified any prior termination notice.
- The Court noted that Garciano's choice not to return to work was voluntary,...continue reading
Case Digest (G.R. No. 96126)
Facts:
The case involves Esteria F. Garciano as the petitioner and Emerito Labajo, Fr. Joseph Wiertz, and several other members of the faculty and Board of Directors of the Immaculate Concepcion Institute as respondents. The events transpired during the 1981-82 school year when Garciano was employed as a teacher at the Immaculate Concepcion Institute located in the Island of Camotes. On January 13, 1982, Garciano applied for an indefinite leave of absence to accompany her daughter to Austria, where her daughter was employed. This application was recommended for approval by the school principal, Emerito Labajo, and subsequently approved by the President of the Board of Directors.
On June 1, 1982, while Garciano was still abroad, Labajo sent a letter to her husband, informing her of the decision made by Fr. Wiertz and the Board to terminate her employment due to the absence of a written contract and the difficulty in finding a substitute teacher. Upon her return in late June 1982, Garciano received this termination letter. However, on July 7, 1982, the Board of Directors, except for Fr. Wiertz, sent her a letter reinstating her to her teaching position effective July 5, 1982, declaring the previous termination letter null and void.
Despite this reinstatement, on July 9, 1982, several members of the Board resigned due to faculty backlash regarding Garciano's reinstatement. On September 3, 1982, Garciano filed a complaint for damages against the respondents in the Regional Trial Court of Cebu, alleging discrimination and illegal dismissal. The trial court ruled in her favor on August 30, ...