Case Digest (G.R. No. 160240)
Facts:
Woodridge School (now known as Woodridge College, Inc.) v. Joanne C. Pe Benito and Randy T. Balaguer, G.R. No. 160240, October 29, 2008, Supreme Court Third Division, Nachura, J., writing for the Court.Petitioner Woodridge School is a private educational institution in Bacoor, Cavite. Respondents Joanne C. Pe Benito and Randy T. Balaguer were hired as probationary high‑school teachers effective June 1998 and June 1999, respectively, under three‑year probationary contracts. Pe Benito taught Chemistry and Physics; Balaguer taught Values Education and Christian Living.
On February 19, 2001 respondents and about twenty other teachers presented a Manifesto Establishing Relevant Issues Concerning the School, raising concerns including an alleged NSAT/NEAT anomaly, lack of due process in disciplining teachers, issuance of individual contracts, and inconsistent school policies. When attempts at internal resolution failed, respondents filed a formal complaint with the Department of Education, Culture and Sports (DECS). While the DECS matter remained pending and petitioner took no apparent corrective action, respondents spoke about the alleged anomaly on television and radio.
In response, on February 28, 2001 petitioner issued separate memoranda placing respondents under preventive suspension for thirty days and asked them to explain within 72 hours why they should not be terminated. Respondents filed an illegal preventive suspension complaint with the NLRC (NLRC NCR Case No. RAB‑IV‑3‑13593‑01‑C) and later amended it to include illegal dismissal after petitioner served Notices of Termination effective March 31, 2001, alleging among other things failure to qualify as regular employees.
The Labor Arbiter dismissed respondents' complaint, finding failure to submit vital teaching documents and serious misconduct (maliciously spreading false accusations via media). The NLRC affirmed the Labor Arbiter in full. Respondents appealed to the Court of Appeals (CA) in CA‑G.R. SP No. 75249; the CA granted the petition, set aside the NLRC resolutions, declared the 30‑day preventive suspension illegal, ordered payment of suspension pay to both respondents, awarded Balaguer backwages for the unexpired portion of his contract, and granted moral and exemplary dama...(Subscriber-Only)
Issues:
- Was the petition procedurally defective because the verification and certificate of non‑forum shopping were signed by only one respondent, and should the petition therefore have been dismissed?
- Was the preventive suspension and subsequent dismissal of respondents valid — i.e., did petitioner establish that respondents failed to qualify as regular employees or that respondents committed serious misconduct justifying preventive suspension and dismissal; and were the awards of ba...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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