G.R. No. L-27155 - Philippine National Bank vs. Court of Appeals

The case was decided by the Supreme Court in G.R. No. 82918, March 11, 1991, involving La Salette of Santiago, Inc. (petitioner) and Clarita Javier (respondent).
The jurisprudence extensively relied on earlier decisions, notably the University of Santo Tomas, et al. v. National Labor Relations Commission, which definitively established the legal principles governing the acquisition of security of tenure by teachers in private educational institutions.
Under Policy Instructions No. 11 and the Manual of Regulations for Private Schools, a teacher attains tenure upon:

The Manual of Regulations further defines “full-time teacher” and sets the appropriate teaching load (e.g., eighteen hours a week in college) to qualify for permanent status.

The standards for evaluating a teacher's satisfactory service are set by the school, a prerogative protected by the doctrines of academic freedom and institutional autonomy.
Although a teacher may be assigned extra duties (e.g., as department head, principal, or administrative officer), such appointments:

Are typically on a temporary or fixed-term basis.
Do not convey an additional security of tenure beyond that already acquired as a teacher.
Remain clearly distinguished from the permanency associated with the regular teaching position unless an additional period of tenure is expressly provided.

Clarita Javier’s career within the La Salette School System spanned over twenty years with various roles, including positions as teacher, subject area coordinator, department head, and administrative officer.
Specific assignments included:

Serving as principal of La Salette of Jones High School (1966–1969).
Working as a teacher and subject area coordinator at La Salette of Santiago, Inc. (1969–1972).
Being employed as a full-time college instructor at La Salette College (1972–1979), including a stint as Head of the College’s Education and Liberal Arts Department (1977–1978).
Assuming the role of Assistant Principal at La Salette of Santiago, Inc. in 1980 while continuing part-time teaching at La Salette College.
Returning as a full-time instructor and later being designated as the High School Principal of La Salette of Santiago, Inc. (1984–1986).

Throughout her career, Clarita Javier was fully aware that while her teaching service was continuous—entitling her to security of tenure as a faculty member—the administrative roles she occupied were temporary and non-permanent.

Upon the expiration of her term as High School Principal (which, according to the system’s rules, was a fixed two-year term), Clarita Javier was informed of her reassignment to La Salette College, where she was to resume teaching on a part-time basis.
Dissatisfied with the sudden change and believing she had acquired tenure as High School Principal, she lodged a complaint for illegal dismissal.
The Executive Labor Arbiter ruled in her favor on January 26, 1987, ordering her reinstatement with full back wages and seniority protections.
The decision was later affirmed by the National Labor Relations Commission (NLRC) in November 1987, which highlighted issues related to managerial prerogative and the employee’s right to humane working conditions.

La Salette of Santiago, Inc. petitioned for certiorari, challenging the NLRC’s affirmation on grounds that the transfer was within its managerial authority.
The Supreme Court reviewed the case, noting that despite Clarita Javier’s continuous service as a teacher qualifying for tenure:

Her administrative positions—by their very nature—were temporary arrangements.
There was no legal basis to extend the security of tenure to her role as High School Principal.

The Court emphasized that the practice in private educational institutions is to differentiate between a tenurable teaching position and a temporary administrative appointment.

Whether Clarita Javier had acquired security of tenure in her capacity as a High School Principal, in addition to her established tenure as a faculty member.
Whether the fixed-term and temporary nature of administrative appointments in the La Salette School System precluded her from claiming additional security of tenure as an administrative officer.
Whether the manner of her transfer and subsequent removal from the administrative post constituted illegal dismissal or amounted to a violation of her right to good and humane working conditions.