Case Digest (G.R. No. 146779)
Facts:
Renato S. Gatbonton v. National Labor Relations Commission, Mapua Institute of Technology and Jose Calderon, G.R. No. 146779, January 23, 2006, Supreme Court First Division, Austria‑Martinez, J., writing for the Court.Petitioner Renato S. Gatbonton was an associate professor in the Faculty of Civil Engineering of respondent Mapua Institute of Technology (MIT). In November 1998 a civil engineering student filed a complaint against petitioner alleging an unfair grading system, sexual harassment and conduct unbecoming of an academician. While the complaint was being investigated, MIT’s Committee on Decorum and Investigation placed petitioner under a 30‑day preventive suspension effective January 11, 1999, reasoning that his continued presence affected his performance and the students’ learning and that suspension would prevent his influence on the community.
Petitioner filed a complaint for illegal suspension, damages and attorney’s fees with the National Labor Relations Commission (NLRC) (NLRC‑NCR Case No. 01‑00388‑99). He also sought relief by filing a petition for certiorari with the Regional Trial Court of Manila; that petition was terminated on May 21, 1999 when the parties executed a compromise agreement under which MIT agreed to publish rules and regulations implementing R.A. No. 7877 (the Anti‑Sexual Harassment Act) and to conduct a new investigation, and petitioner recognized the authority of MIT to proceed under the published rules.
On June 18, 1999 the Labor Arbiter declared the 30‑day preventive suspension illegal and ordered respondents to pay petitioner his wages for the suspension period; the Arbiter dismissed the other claims. Both sides appealed to the NLRC; on September 30, 1999 the NLRC granted respondents’ appeal and set aside the Labor Arbiter’s decision. The NLRC denied reconsideration on December 13, 1999. Petitioner then filed a special civil action for certiorari with the Court of Appeals (CA), which on November 10, 2000 denied the petition and affirmed the NLRC’s decision; the CA denied reconsideration on January 16, 2001.
Petitioner sought relief from the Court by a petition for review on certiorari under Rule 45, assigning as grounds that the CA and NLRC committed grave abuse of discr...(Pro-only)
Issues:
- Did the Court of Appeals and the NLRC commit grave abuse of discretion in setting aside the Labor Arbiter’s decision?
- Was petitioner’s preventive suspension valid given that MIT’s implementing rules were published only on February 23, 1999?
- Is petitioner entitled to moral or other damages for th...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)