Title
Supreme Court
Leus vs. St. Scholastica's College Westgrove
Case
G.R. No. 187226
Decision Date
Jan 28, 2015
A Catholic school employee was dismissed for pre-marital pregnancy; the Supreme Court ruled her termination illegal, stating private conduct did not affect her job or the institution.

Case Digest (G.R. No. 187226)
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)

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