G.R. No. 193237 - Jalosjos, Jr. vs. Commission on Elections

Petitioner: International Catholic Migration Commission (ICMC), a non-profit organization dedicated to refugee service at the Philippine Refugee Processing Center in Morong, Bataan.
Respondent: Bernadette Galang, a private employee engaged as a cultural orientation teacher.
Date of Engagement: January 24, 1983, under a probationary appointment with a monthly salary of P2,000.00.

The employment was agreed to be on a probationary basis for a period of six months under a verbal contract.
The purpose of the probationary period was to assess the respondent’s qualification for regular employment, based on the employer’s temporarily established performance evaluation system.

Approximately three months into her employment, during a teacher evaluation program involving newly-hired personnel, the respondent’s performance was scrutinized by her supervisors.
Evaluations highlighted deficiencies in classroom management, teacher-student relationships, and teaching techniques.
On April 22, 1983, the respondent was informed—both orally and in writing—that her services were being terminated due to her failure to meet the prescribed (reasonable) standards required for regular employment.

Despite her termination, the respondent did not immediately leave the ICMC refugee camp but lingered for a few days before departing for Manila.
During this period, she was observed by the petitioner allegedly acting strangely.
On July 24, 1983, she returned to Morong aboard the petitioner’s service bus to complete clearance requirements and was later found at Freedom Park, wet and shivering from the rain, exhibiting odd behavior.
The petitioner took her to the camp hospital to receive necessary medical attention.
On July 26, 1983, she was transported to her residence in Manila, again via the petitioner’s service bus.
A letter from her father, acknowledging the petitioner’s care, was received along with a payment covering her proportionate 13th month pay and a two-week salary.

Date of Complaint Filing: August 22, 1983.
Claims Filed: Illegal dismissal, unfair labor practice, and unpaid wages.
Relief Sought: Reinstatement with backwages, exemplary and moral damages.
Labor Arbiter’s Decision (October 8, 1983): Dismissed the illegal dismissal as well as moral and exemplary damages claims, but ordered the petitioner to pay the respondent P6,000.00, representing the salary for the last three months of the agreed employment period.

Both parties appealed the Labor Arbiter’s decision to the National Labor Relations Commission (NLRC).
Arguments in Appeal:

The respondent contended that her dismissal was illegal since it was effected without a valid cause.
The petitioner maintained that termination during the probationary period was proper because the respondent failed to qualify as a regular employee as per the employer’s reasonable standards.

Majority (Commissioners Medina and Gatchalian): Sustained the Labor Arbiter’s award ordering payment of P6,000.00 for the unexpired portion of the contract.
Dissent (Commissioner Varela): Argued for reversal of the decision, asserting that the termination was effected on valid grounds during the probationary period.

Petitioner subsequently filed the present petition challenging the NLRC’s award.
The petitioner argued that the respondent was not entitled to payment for the unworked period of her probationary employment because her termination was justified under Article 281 (formerly Article 282) of the Labor Code.
The petitioner maintained that awarding such salary would result in unjust enrichment and contradict the trial nature of probationary employment.

Whether a probationary employee who is terminated for failing to meet the prescribed standards of employment is entitled to receive her salary for the unexpired portion of the probationary period.
Whether the termination of the respondent, effected at three months into a six-month probationary period, was legally justified under the provisions of the Labor Code.
Whether the petitioner, by terminating the respondent for failure to qualify as a regular employee, is liable for the payment of salary for the period after termination, given the nature of probationary employment as a trial period.