Case Digest (G.R. No. 187226)
Facts:
Cheryll Santos Leus v. St. Scholasticas College Westgrove and/or Sr. Edna Quiambao, OSB, G.R. No. 187226, January 28, 2015, Supreme Court Third Division, Reyes, J., writing for the Court.
Petitioner Cheryll Santos Leus was engaged by St. Scholasticas College Westgrove (SSCW), a Catholic sectarian school, in May 2001 as an assistant to the Director of the Lay Apostolate and Community Outreach Directorate. In 2003 she became pregnant out of wedlock. When SSCW learned of her pregnancy, its directress, Sr. Edna Quiambao, advised petitioner to resign effective June 1, 2003; petitioner refused. On May 28, 2003 Sr. Quiambao directed petitioner to explain in writing why she should not be dismissed for engaging in pre‑marital sexual relations and becoming pregnant, which SSCW characterized as serious misconduct or disgraceful/immoral conduct under its applicable rules.
Petitioner submitted explanations (through counsel) denying that premarital sex between consenting adults who later married constituted disgraceful or immoral conduct warranting dismissal and requested a copy of SSCW’s policy. SSCW replied that, pending a Support Staff Handbook, it followed the 1992 Manual of Regulations for Private Schools (1992 MRPS), specifically Section 94(e) (disgraceful or immoral conduct), as an additional ground for dismissal. On June 11, 2003 SSCW terminated petitioner for serious misconduct/disgraceful or immoral conduct.
Petitioner filed a complaint for illegal dismissal with the Regional Arbitration Branch of the NLRC (Labor Arbiter docket). The Labor Arbiter (Decision dated February 28, 2006, LA Danna M. Castillon) dismissed petitioner’s complaint, finding pregnancy out of wedlock a disgraceful/immoral conduct given the school’s nature and petitioner’s role. The NLRC affirmed in a Resolution dated February 28, 2007 and denied reconsideration on May 21, 2007, holding that Section 94(e) of the 1992 MRPS governed and that petitioner’s pregnancy was disgraceful or immoral.
Petitioner then filed a petition for certiorari with the Court of Appeals (CA-G.R. SP No. 100188). The CA denied the petition in its Decision dated September 24, 2008 and denied reconsideration in Resolution dated March...(Pro-only)
Issues:
- Was the CA correct in holding that the 1992 MRPS (particularly Section 94) — not the general provisions of the Labor Code — governs the termination of employment of teaching and non‑teaching personnel of private schools?
- Did petitioner’s pregnancy out of wedlock (and premarital sexual relations) constitute a valid ground for dismissal as “disgraceful or immoral conduct” under Section 94(e) of the 1992 MRPS, and was her dismissal a valid exe...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)