Case Digest (G.R. No. 223665)
Facts:
University of the Cordilleras, Dr. Ricardo Pama, Dr. Cleofas M. Basaen, Dr. Miriam A. Janeo v. Benedicto F. Lacanaria, G.R. No. 223665, September 27, 2021, Supreme Court Second Division, Hernando, J., writing for the Court.Petitioner University of the Cordilleras employed respondent Benedicto F. Lacanaria as an Instructor‑Associate Professor in the College of Teacher Education beginning June 2005. On February 25, 2010 a student, Rafael Flores, collapsed during a class creative presentation; Flores reportedly had a persistent cough and later sought medical attention at a hospital. Lacanaria told Flores to sit and at one point said “umupo ka muna dyan, hindi ka pa naman mamamatay,” allowed him to go to the clinic but did not promptly attend to him, and later allegedly told him “tae mo!” when Flores tried to report what had happened.
Flores filed a written complaint (early March 2010) supported by classmates’ affidavits and a video. The University issued a Charge Sheet with Notice of Investigation (March 11, 2010) for serious misconduct and violation of the Faculty Manual and Code of Ethics for Professional Teachers. The Grievance Committee set hearings (March 30 and April 7, 2010); Lacanaria alleges inadequate notice (text messages and registered mail delivered less than five days before hearings) and thus did not attend; the Committee nonetheless took affidavits and recommended dismissal. A Notice of Decision dated May 15, 2010, signed by the VP for Administration, informed Lacanaria of dismissal; he received it May 21, 2010. He filed a motion for reconsideration (May 31, 2010) and a later letter withdrawing his intent to resign; the President denied reconsideration in a Resolution dated June 24, 2010.
Lacanaria filed a complaint for illegal dismissal before the Department of Labor and Employment (June 9, 2010). The Executive Labor Arbiter (ELA) dismissed his complaint but ordered payment of proportionate 13th month pay (Decision, December 30, 2010). The NLRC affirmed the ELA (Resolution, October 21, 2011; denial of reconsideration January 10, 2012). Lacanaria then appealed to the Court of Appeals (CA), which reversed the NLRC in a March 18, 2016 Decision: the CA found no just cause, concluded Lacanaria was denied due process (defective notices, improper decision signatory, de facto denial of teaching load tantamount to preventive suspension), and ordered reinstatement, backwages, moral and exemplary damages, and attorney’s fees. The University filed a Petition for Review on Certiorari under Rule 45 to the Supreme Court, contesting (a) existence ...(Pro-only)
Issues:
- Was Lacanaria’s dismissal tainted with procedural due process defects (notice of hearing, identity of the decision‑maker, and related procedural acts)?
- Was there substantial evidence to dismiss Lacanaria for serious misconduct or conduct unbecoming of an academician?
- Given the Court’s findings on procedural and substantive issues, is Lacanaria entitled to reinstatement, back...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)