Case Digest (G.R. No. 252124)
Facts:
Bohol Wisdom School, Dr. Simplicio Yap, Jr., and Raul H. Deloso, G.R. No. 252124, July 23, 2024, First Division, Rosario, J., writing for the Court. Respondent Miraflor D. Mabao, a grade school teacher at Bohol Wisdom School (BWS) since June 7, 2007 and a regular employee since 2010, was suspended by school officials in September 2016 after she informed the administration that she was two months pregnant and that she and her boyfriend intended to marry. The Administrative Team met on September 21, 2016 and, according to the school, agreed to suspend her from September 22, 2016 until she was legally married; Mabao was later given a Disciplinary Form and a Letter describing the suspension as “indefinite until legally married.”Mabao filed a complaint with the Labor Arbiter on October 5, 2016 for illegal suspension and illegal dismissal, among other monetary claims. The Labor Arbiter found constructive dismissal and awarded backwages, separation pay and other benefits in a Decision dated January 31, 2017. BWS et al. appealed to the National Labor Relations Commission (NLRC).
The NLRC, in a Decision dated May 31, 2017, granted the employer’s appeal, reversed the Labor Arbiter and deleted the monetary award, finding no evidence of constructive dismissal and that the school intended to accept Mabao back once married. Mabao’s motion for reconsideration before the NLRC was denied on July 17, 2017.
Mabao filed a petition for certiorari with the Court of Appeals (CA) alleging grave abuse of discretion by the NLRC. The CA in its September 28, 2018 Decision partly granted the petition: it affirmed that there was no constructive dismissal but ruled that Mabao had been illegally suspended on the ground that premarital sex resulting in pregnancy was not immoral under public and secular standards and because procedural due process was not observed; the CA ordered prorated backwages and other benefits, attorney’s fees, and a certificate of employment. The CA denied the parties’ motions for reconsideration in a January 24, 2020 Resolution.
BWS et al. elevated the case to the Supreme Court by a Petition for Review on Certio...(Pro-only)
Issues:
- May the Supreme Court review factual findings on a Rule 45 petition?
- Was Miraflor D. Mabao illegally suspended by Bohol Wisdom School on grounds of premarital sexual relations and pregnancy out of wedlock?
- Did Bohol Wisdom School comply with procedural due process before imposing suspension on Mabao?
- Did Mabao’s conduct and subsequent acts amount to abandonment or constructive dismissal, and what is the correct last day of employment for purposes of computing benefits?
- Are Mabao’s monetary awards and attorne...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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