G.R. No. 75093 - Sibal vs. Notre Dame of Greater Manila

Petitioner Delia R. Sibal was employed as a school nurse by Notre Dame of Greater Manila beginning in January 1973.
Initially, she was paid on a 12-month basis despite working only during the ten-month school period, with no obligations during Christmas and summer vacations.
On March 10, 1976, Fr. Enrique Gonzales, then director, requested that she shorten her summer vacation. Petitioner complied with the request.

In April 1980, Fr. Gonzales ordered petitioner to assist in the library during summer. Petitioner contested the order by pointing out that library work was alien to her expertise as a nurse; her objection led to the director relenting.
In November 1980, with the appointment of Fr. Pablo Garcia as the new director, petitioner was again directed to report during the summer before the next school year.

Petitioner asserted that her contract did not require summer work and filed leaves of absence for the period to prevent any misunderstanding.
She also did not receive her due vacation pay for the summer months worked or omitted.

During the school year 1981-1982, petitioner was assigned the additional duty of teaching health subjects to 900 students across 19 sections.

Other teachers received extra compensation for additional work; however, petitioner was not compensated for the extra teaching load.
Repeated attempts to resolve her claims—regarding unpaid vacation pay and additional teaching compensation—were met with inaction or dismissive responses from the administration.

In April 1982, Fr. Garcia again ordered petitioner to work during the summer to update clinical records despite her protest, citing that it was the ideal time due to lack of student disturbance.

Petitioner reiterated in her letters that her employment contract did not require summer work and reminded the director of her unresolved claims regarding teaching compensation and vacation pay.
The director issued warnings and threatened adverse measures if she did not comply.

On June 14, 1982, while petitioner was reporting for work on the opening day of classes, she was served her termination letter with immediate effect and the matter was forwarded to the Ministry of Labor and Employment.
Following her termination, petitioner amended her complaint to include charges of illegal dismissal and unfair labor practice.
Despite various memorandum and position papers filed by both petitioner and respondents, the Labor Arbiter’s decision on October 8, 1982, and its subsequent affirmation by the NLRC on April 11, 1986, controversially awarded separation pay in lieu of reinstatement and dismissed her claims for teaching compensation and moral damages.

Petitioner contended that awarding separation pay instead of reinstatement undermined the constitutional guarantee of security of tenure.
She argued that compensation for teaching health subjects was distinct from her nursing duties and legally due.
Further, she alleged that she was subject to harassment and fabricated charges amounting to unfair labor practices warranting moral damages.
Public respondent NLRC countered that reinstatement would impose undue burden, that teaching was intertwined with her regular duties, and that she failed to prove union membership necessary to establish unfair labor practice.

Multiple communications, filing of memoranda, and position papers ensued between petitioner and school administration.
Significant personnel changes occurred when Fr. Garcia was replaced by Fr. Jose Arong on September 8, 1983, after mounting opposition from the faculty and staff.
The case was eventually elevated to the Court on petitioner’s certiorari petition filed on July 15, 1986.

Whether the award of separation pay, rather than reinstatement with backwages, is the proper remedy under the circumstances.
Whether petitioner is entitled to additional compensation for teaching health subjects, despite such teaching being allied to her duties as a school nurse.
Whether the acts of termination, in light of the contested proceedings, constitute unfair labor practices justifying an award of moral damages.