Case Digest (G.R. No. 252124) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves petitioners Bohol Wisdom School (BWS), Dr. Simplicio Yap, Jr. (Chairman of its Board of Trustees), and Raul H. Deloso (Head of its Administrative Team) against respondent Miraflor Mabao, a former grade school teacher at BWS. Mabao started working at BWS on June 7, 2007, became a regular employee in 2010, and was assigned as adviser for Grades 1 and 2. She was suspended on September 22, 2016, after informing the school of her pregnancy out of wedlock. Mabao was suspended indefinitely without pay until she legally married the father of her child, her boyfriend Ian Usaraga. The suspension was based on a disciplinary action citing premarital relations and pregnancy outside of marriage as grounds for immorality, which the school deemed grounds for disciplinary sanction. Mabao filed a complaint before the National Labor Relations Commission (NLRC) on October 5, 2016, accusing BWS and its officers of illegal suspension and illegal dismissal, seeking backwages, separat Case Digest (G.R. No. 252124) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of the Case
- Petitioners: Bohol Wisdom School (BWS), Dr. Simplicio Yap, Jr. (Chairman of the Board), and Raul H. Deloso (Head of Administrative Team).
- Respondent: Miraflor Mabao, a former grade school teacher of BWS.
- Case: Complaint for illegal suspension and illegal dismissal filed by Mabao against BWS et al.
- Mabao’s Employment Background and Suspension
- Mabao started working at BWS on June 7, 2007, and was granted regular status in 2010.
- She taught subjects like Language 2, Physical Education 2, Arts 3, Mother Tongue, and Writing 2.
- On September 21, 2016, Mabao informed the administration of her two-month pregnancy from her boyfriend, Ian Usaraga.
- On September 22, 2016, Mabao was verbally suspended by Deloso and told she could not report to work until she presented documents showing she was legally married.
- On September 27, 2016, Mabao was served a disciplinary form and a letter stating indefinite suspension without pay until marriage.
- The disciplinary form cited engagement in pre-marital relations resulting in pregnancy as grounds for suspension.
- Mabao’s Complaint
- Filed on October 5, 2016 with the National Labor Relations Commission (NLRC) for illegal suspension, illegal dismissal, unpaid benefits, damages, and attorney’s fees.
- BWS et al.’s Version
- Mabao confessed pregnancy out of wedlock but was in process of obtaining a marriage license.
- Suspension was agreed upon to avoid questions from students and lasted until marriage.
- Mabao was given multiple return-to-work notices after her marriage on October 5, 2016, all refused.
- Mabao never returned to work after marriage despite notices.
- Proceedings and Findings Prior to Supreme Court Review
- Labor Arbiter ruled Mabao was constructively dismissed and awarded damages.
- NLRC reversed Labor Arbiter, finding no constructive dismissal — only suspension.
- Court of Appeals (CA) affirmed no constructive dismissal but ruled suspension illegal, awarding backwages and benefits till November 25, 2016.
Issues:
- Whether Mabao’s suspension was illegal.
- Whether constructive dismissal occurred.
- Whether procedural due process was observed by BWS et al.
- Whether Mabao abandoned her employment.
- Proper computation period for monetary awards.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)