Case Digest (G.R. No. 115795) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Petitioner Jose S. Santos, Jr. was employed as a teacher by Hagonoy Institute, Inc. from June 1980 until his dismissal effective June 1, 1991. During his tenure he allegedly entered into an extra-marital affair with his co-teacher, Mrs. Arlene T. Martin, both being married. Rumors of their relationship spread among faculty, prompting the school’s Directress, Marta B. Zuniga, and Principal Elisea B. Banag to form an investigative committee. After two weeks, the committee confirmed the illicit liaison. Mrs. Martin was summarily dismissed in November 1990 without due process and later succeeded in her illegal dismissal case before the NLRC. Thereafter, petitioner was served an administrative charge for immorality, given opportunity to be heard in May 1991, and subsequently terminated. Petitioner then filed for illegal dismissal before the NLRC’s Regional Arbitration Branch in Pampanga; the Labor Arbiter dismissed his complaint but awarded financial assistance of ₱13,750.00. On appe Case Digest (G.R. No. 115795) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Employment and Relationship
- Petitioner Jose S. Santos, Jr., a married teacher, employed by Hagonoy Institute Inc. from June 1980 until his dismissal on June 1, 1991.
- Mrs. Arlene T. Martin, also a married teacher at the same school, and petitioner developed an illicit relationship; rumors circulated among faculty and officials.
- Mrs. Martin’s Dismissal and Proceedings
- On November 3, 1990, Mrs. Martin was advised to take leave; she continued reporting and was barred from the premises on November 9, 1990 (effectively dismissed).
- She filed for illegal dismissal on November 13, 1990 before NLRC Regional Arbitration Branch No. III, which initially dismissed her complaint but granted financial assistance; on appeal (February 26, 1993) NLRC reversed for lack of due process and ordered backwages and separation pay.
- Petitioner’s Administrative Charge, Dismissal, and Labor Cases
- A school committee investigated for two weeks, confirmed the illicit relationship, and on December 19, 1990 charged petitioner with immorality; after hearings, petitioner was notified in May 1991 of his dismissal effective June 1, 1991.
- Petitioner filed an illegal dismissal complaint on August 12, 1991 before NLRC Regional Arbitration Branch No. III; Labor Arbiter Mendoza dismissed the complaint on January 12, 1993 but awarded P13,750 as financial assistance; NLRC on November 29, 1993 dismissed petitioner’s appeal for lack of merit; motion for reconsideration denied; petition for certiorari under Rule 65 filed with the Supreme Court.
Issues:
- Whether petitioner’s extra-marital relationship constitutes "immorality" amounting to just cause for dismissal under Article 282 of the Labor Code and Section 94(E) of the DECS Manual.
- Whether petitioner was accorded the requisite procedural due process before termination.
- Whether financial assistance (separation pay) was properly awarded despite dismissal for misconduct involving moral turpitude.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)