G.R. No. 231144 - Republic vs. Sandiganbayan, Special 2nd Division

Grace de Guzman was initially engaged by PT&T as a Supernumerary Project Worker (reliever) from November 21, 1990 to April 20, 1991, replacing an employee on maternity leave.
She again served as reliever during June 10–July 1, 1991 and July 19–August 8, 1991, pursuant to fixed‐term Reliever Agreements.
On September 2, 1991, she was rehired as a probationary employee for a 150-day period. In her job application and reliever agreements, she indicated she was single despite having married on May 26, 1991.

On January 15, 1992, the branch supervisor issued a memorandum demanding explanation for the discrepancy in her civil status and reminding her of PT&T’s policy of not accepting married women.
In her January 17, 1992 reply, de Guzman asserted she was unaware of the policy and had no intent to hide her marriage.
PT&T dismissed her effective January 29, 1992, ostensibly for dishonesty (failure to disclose marriage) and alleged defalcation of P2,380.75, which de Guzman acknowledged via promissory note.

De Guzman filed for illegal dismissal and unpaid COLA; at the preliminary conference she admitted non‐remittance of collections and signed a promissory note.
On November 23, 1993, the Labor Arbiter ruled her dismissal illegal, ordered reinstatement with full back wages and COLA, finding discrimination for contracting marriage.
On April 29, 1994, the NLRC affirmed but modified the remedy, imposing a three‐month suspension for the dishonest concealment. A motion for reconsideration was denied on November 9, 1994.

Whether PT&T validly terminated de Guzman for just cause (dishonesty/defalcation) or whether the real ground was proscription of married women.
Whether a company policy barring married women employees violates Article 136 of the Labor Code (stipulation against marriage).
Whether de Guzman had acquired regular employment status entitling her to security of tenure and full back wages.