Case Digest (G.R. No. 187226) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Cheryll Santos Leus v. St. Scholastica’s College Westgrove and/or Sr. Edna Quiambao, OSB, decided January 28, 2015 by the Supreme Court under G.R. No. 187226, the petitioner, Cheryll Santos Leus, was hired in May 2001 as Assistant to the Director of Lay Apostolate and Community Outreach at St. Scholastica’s College Westgrove (SSCW), a Catholic, sectarian school in Silang, Cavite. In 2003, upon learning that the petitioner had engaged in pre-marital sexual relations and became pregnant out of wedlock, SSCW’s Directress, Sr. Edna Quiambao, advised her to resign effective June 1, 2003. The petitioner refused and was formally asked on May 28, 2003 to explain why she should not be dismissed for serious misconduct and conduct unbecoming an employee of a Catholic institution. Through counsel, the petitioner argued that no school policy classified her pregnancy as misconduct. SSCW responded that under Section 94(e) of the 1992 Manual of Regulations for Private Schools (1992 MRPS), “d Case Digest (G.R. No. 187226) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment and allegation of misconduct
- In May 2001, St. Scholastica’s College Westgrove (SSCW), a Catholic educational institution in Cavite, hired Cheryll Santos Leus (petitioner) as Assistant to the Director of the Lay Apostolate and Community Outreach.
- In 2003, petitioner engaged in pre-marital sexual relations, became pregnant out of wedlock, and subsequently married the father of her child.
- Termination process
- Upon learning of the pregnancy, SSCW’s Directress, Sr. Edna Quiambao, advised petitioner to resign effective June 1, 2003; petitioner refused.
- On May 28, 2003, petitioner was asked to explain in writing why she should not be dismissed for “serious misconduct” and “immoral conduct” under the 1992 Manual of Regulations for Private Schools (MRPS), § 94(e).
- Petitioner’s written explanations (May 31 and June 4, 2003) argued no school policy prohibited premarital sex and stressed her subsequent marriage.
- SSCW maintained that as a Catholic institution it could dismiss employees for conduct contrary to Church teachings.
- Labor and appellate proceedings
- June 11, 2003: Petitioner’s employment was terminated for serious misconduct.
- February 28, 2006: Labor Arbiter upheld the dismissal, finding pregnancy out of wedlock “disgraceful and immoral” relative to SSCW’s Catholic identity.
- February 28 and May 21, 2007: NLRC affirmed the Arbiter, citing MRPS § 94(e).
- September 24, 2008 and March 2, 2009: Court of Appeals denied petitioner’s Rule 45 petition, ruling MRPS applies over the Labor Code and that petitioner’s conduct was scandalous per se.
- January 28, 2015: Petitioner filed a petition for certiorari under Rule 45 before the Supreme Court.
Issues:
- Whether the 1992 MRPS governs termination of private school personnel over the Labor Code.
- Whether pregnancy out of wedlock constitutes a valid ground for dismissal under MRPS § 94(e).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)