Case Digest (G.R. No. 82918)
Facts:
La Salette of Santiago, Inc. v. National Labor Relations Commission and Clarita Javier, G.R. No. 82918, March 11, 1991, Supreme Court First Division, Narvasa, C.J., writing for the Court.Petitioner is La Salette of Santiago, Inc.; respondents are the National Labor Relations Commission (NLRC) and Clarita Javier (complainant). Clarita Javier had a long, intermittent employment relationship within the La Salette school system, serving at various times as a full-time teacher, department head, college instructor, subject-area coordinator, assistant principal and high school principal across sister schools in the system.
Chronology: Javier served as high school principal and in other administrative posts at various times between the mid-1960s and 1986, and also taught (sometimes part‑time) in the college. The Manual of Regulations for Private Schools (and Department of Labor Policy Instructions No. 11) was treated as the governing standard for acquisition of security of tenure by teachers. Javier’s last appointment as High School Principal of La Salette of Santiago was for a fixed two‑year term (June 1, 1985 to May 31, 1986). After the term expired, the Board notified her to report to La Salette College and assigned a nun to replace her as principal. Javier refused the assignment back to college and filed a complaint for illegal dismissal on June 18, 1986.
At the administrative level, the Executive Labor Arbiter rendered judgment in Javier’s favor on January 26, 1987 ordering reinstatement to the principalship with back wages and attorney’s fees. The NLRC affirmed the Arbiter by Resolution dated November 18, 1987, finding that the transfer caused Javier distress and violated her right to humane working conditions; the NLRC denied recon...(Subscriber-Only)
Issues:
- Did the NLRC commit grave abuse of discretion amounting to lack or excess of jurisdiction in affirming the Executive Labor Arbiter’s reinstatement order?
- Did Clarita Javier acquire security of tenure as High School Principal (a separate, additional tenure) apart from her tenure...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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