G.R. No. 167286 - International School Manila vs. International School Alliance of Educators

Petitioner International School Manila ("the School") employed respondent Evangeline Santos as a Spanish language teacher starting in 1978.
Santos took a leave of absence for the 1992-1993 school year and returned in August 1993.
Upon return, she agreed to teach one Spanish class and four Filipino classes, the latter being new to her.
Her teaching of Filipino was closely supervised and evaluated through Classroom Standards Evaluation Forms covering areas like Planning, Teaching Act, Climate, Management, and Communication.

From 1993 to 1997, various school officials, particularly Assistant Principal Dale Hill and later Peter Loy, assessed Santos’ teaching.
Recurring deficiencies included inadequately detailed lesson plans, ineffective questioning techniques, poor classroom management, unclear expectations for students, and substandard instructional sequencing.
Despite repeated observations noting the need for improvement in punctuality, planning, and teaching methods, Santos was subject to multiple memos addressing these deficiencies.
On March 29, 1996, Santos was placed under a Professional Growth Plan aimed at remediation, focusing initially on improving her lesson planning.
There were initial signs of improvement per memos dated April and May 1996, though subsequent observations revealed persistent shortcomings.

Santos was repeatedly reminded to improve lesson plans, maintain detailed daily lesson plans, and address concerns from observations.
In late 1996 and early 1997, her lesson plans were criticized as vague, incomplete, and lacking coherence.
Senior administrators including Principal Jeffrey Hammett and Assistant Principal Loy expressed frustration over her failure to sustain improvement.
On April 10, 1997, Santos was directed by the School to explain why her employment should not be terminated due to her inadequate teaching performance.
An administrative investigation was held on April 23, 1997, where Santos was assisted by the ISAE President. The charge was gross inefficiency or negligence.
On May 29, 1997, the School formally notified Santos of the termination of her employment effective June 7, 1997, due to failure to improve despite remediation efforts.

On June 26, 1997, the International School Alliance of Educators (ISAE) filed a complaint for unfair labor practice, illegal dismissal, and damages, docketed as NLRC-NCR Case No. 00-06-04491-97.
Santos, along with other complainants, amended the complaint to include claims of illegal dismissal.
The Labor Arbiter ruled that Santos was illegally dismissed, stating that her inefficiency was neither gross nor habitual. The award included separation pay and limited backwages.
On appeal, the NLRC affirmed the Labor Arbiter’s decision citing insufficient evidence of gross and habitual neglect.
The Court of Appeals likewise affirmed the decision with modification, ordering separation pay instead of reinstatement due to strained relations but rejecting the claim of a lawful dismissal.

The School and Brian McCauley filed a petition for review on certiorari before the Supreme Court, challenging the rulings on the illegality of Santos’ dismissal and entitlements.

Whether the Court of Appeals erred in finding that respondent Evangeline Santos was illegally dismissed.
Whether respondent Evangeline Santos is entitled to reinstatement or separation pay with backwages.