Case Digest (G.R. No. 223665) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In University of the Cordilleras, Dr. Ricardo Pama, et al. v. Benedicto F. Lacanaria (G.R. No. 223665, September 27, 2021), respondent Benedicto Lacanaria was employed in June 2005 as an Instructor-Associate Professor at the petitioner University’s College of Teacher Education. On February 25, 2010, during a class creative presentation, a student, Rafael Flores, collapsed due to a persistent cough. Professor Lacanaria allegedly dismissed the incident by telling the student “umupo ka muna diyan, hindi ka pa naman mamamatay,” prevented classmates from assisting him, and later uttered “tae mo!” when the student tried to explain. Flores filed a written complaint on March 3–5, 2010. On March 11, 2010, the University served Lacanaria a Charge Sheet for *serious misconduct* and violation of the *Code of Ethics for Professional Teachers.* Though directed to answer and attend investigation hearings on March 30 and April 7, 2010, Lacanaria did not appear, claiming lack of proper notice. T Case Digest (G.R. No. 223665) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment and Classroom Incident
- The University of the Cordilleras hired Benedicto F. Lacanaria in June 2005 as an Instructor-Associate Professor at the College of Teacher Education.
- On February 25, 2010, during a student presentation, Rafael Flores—who had a persistent cough—collapsed when asked to dance. Lacanaria dismissed the collapse, told the next group to perform, initially refused clinic permission (“umupo ka muna dyan, hindi ka pa naman mamamatay”), and later uttered “tae mo!” when Flores sought to explain. Flores was diagnosed with costochondritis and an upper respiratory tract infection.
- Administrative Charges and University Proceedings
- On March 11, 2010, the University served Lacanaria a Charge Sheet for serious misconduct and Code of Ethics violations, directing him to answer within five days and attend investigative hearings. Notices of hearings on March 30 and April 7 were issued—one by text message (unproven receipt) and one by registered mail (received the day of hearing). Lacanaria failed to appear.
- The Grievance Committee’s undated Report and Recommendation found Lacanaria guilty and recommended dismissal. The Vice President for Administration issued a Notice of Decision dated May 15, 2010 dismissing Lacanaria effective May 15. Lacanaria allegedly received it on May 21, 2010. He withdrew his letter of resignation (filed March 12) on May 31 and filed a Motion for Reconsideration. The University President denied reconsideration on June 24, 2010.
- Labor and Judicial Recourse
- On June 9, 2010, Lacanaria filed a complaint for illegal dismissal before the Department of Labor and Employment. The Executive Labor Arbiter (ELA) on December 30, 2010 dismissed the complaint for lack of merit but awarded 13th month pay.
- The NLRC affirmed the ELA in Resolutions of October 21, 2011 and January 10, 2012. The Court of Appeals (CA) reversed on March 18, 2016, declaring the dismissal without just cause and awarding reinstatement, backwages, moral and exemplary damages, and attorney’s fees. The University then filed this Petition for Review on Certiorari under Rule 45.
Issues:
- Whether substantial evidence supports Lacanaria’s dismissal for serious misconduct and conduct unbecoming of an academician.
- Whether procedural defects—specifically failure to comply with Faculty Manual requirements on date, place, and time of investigation—tainted the dismissal.
- Whether Lacanaria is entitled to reinstatement, moral and exemplary damages, and attorney’s fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)