G.R. No. 6364 - Gumiran vs. Gumiran

Spouses Alwyn Ong Lim and Evelyn Lukang Lim were hired in June 1999 by Legazpi Hope Christian School.
Alwyn was assigned to teach Mathematics, Geometry, Algebra, and Trigonometry in the high school department.
Evelyn was assigned to teach Chinese Language 1 and 2 and Chinese Math in the elementary department.

On April 4, 2002, respondent Helen Sia, head teacher of the school’s Chinese department, verbally informed the petitioners of the termination of their employment without stating reasons.
The petitioners filed complaints for illegal dismissal and monetary claims against the school and its officials on April 5, 2002.
On May 31, 2002, respondent Ramon Sia, Vice Chairman of the school’s Board of Directors, sent a letter stating that the petitioners’ three-year probation had expired and that the school had decided to discontinue their employment.

In the initial proceedings, respondents argued that the petitioners were merely part-time teachers who had not acquired permanent status and, thus, could be dismissed prior to completing the three-year probationary period.
The Labor Arbiter ruled in favor of the petitioners and ordered relief including reinstatement and back wages, along with moral and exemplary damages and attorney’s fees.
The dispositive portion of the Consolidated Decision of November 7, 2003 ordered reinstatement without loss of seniority and awarded monetary claims.

Respondents appealed the Labor Arbiter’s decision to the National Labor Relations Commission (NLRC).
The NLRC found that since the petitioners were part-time teachers, they did not acquire permanent status; hence, their dismissal was legal.
The NLRC modified the earlier decision by awarding proportionate 13th month pay and service incentive leave pay based on their reported monthly salaries, while dismissing illegal dismissal, damages, and attorney’s fees claims.
Petitioners’ motion for reconsideration was denied in a Resolution dated November 30, 2004.
The Court of Appeals subsequently affirmed the NLRC decision, particularly the disposition of NLRC RAB V Cases Nos. 04-00239-02 and 04-00240-02 involving the petitioners.

Petitioners contended that no formal written probationary contract was issued and argued that, upon completing the three-year period, they should be considered as permanent, full-time employees.
They also claimed to be performing non-teaching functions and maintained that their work schedules and duties were more consistent with full-time teaching responsibilities.
Respondents, however, maintained that under the Manual of Regulations for Private Schools, the designation of full-time versus part-time depends on teaching load and work hours.
Evidence included the “Teachers’ Guidelines” which indicated that new teachers were on one-year contracts subject to re-application and that assignment as full-time or part-time depended on actual teaching loads.

Whether or not the petitioners were hired as permanent teaching personnel based on the established facts.

The determination centered on whether the petitioners were full-time employees or merely part-time instructors.
The evidence regarding their work schedules was examined to ascertain if they met the full-time criteria under the Manual of Regulations for Private Schools.

Whether or not the petitioners were terminated without lawful and just cause and in violation of their due process rights.

This issue questioned the procedural and substantive regularity of their termination.
The absence of a formal written probationary contract and unclear evaluation standards were scrutinized.

Whether or not the petitioners are entitled to the relief of reinstatement with back wages from the time of termination until actual reinstatement, as well as other benefits including moral/exemplary damages and attorney’s fees.

The contention of entitlement to full reinstatement was weighed against the status as part-time teachers.
The claims for additional monetary relief were also subject to examination under relevant labor precedents and contractual arrangements.