Case Summary (G.R. No. 178837)
Factual Background
The respondent was initially hired by petitioner as a probationary teacher in 1971 and was eventually promoted to Master Teacher in 1982. Her employment consisted of intermittent periods, with her last stint starting as a substitute teacher in October 1999 and progressing until her termination in October 2003. The employment relationship soured on September 10, 2003, when complaints from parents concerning respondent's handling of class records surfaced, particularly allegations of unprofessionalism and discrepancies in student grades.
Investigation and Grounds for Termination
Petitioner's investigation revealed significant discrepancies in respondent's grading records. These discrepancies between her "Dirty Records" and "Clean Records" indicated cases of grade tampering to favor certain students, notably one Louis Ariel Arellano, who was inaccurately portrayed as the top pupil. Subsequently, on September 12, 2003, petitioner issued a notice requiring respondent to explain these discrepancies, but she refused to accept the notice. The letter was later delivered by registered mail.
Procedural Engagement
After failing to present her explanation, the principal summoned respondent for a conference on October 2, 2003, where termination was discussed. Despite assurances of the validity of her performance, respondent was ultimately fired on October 3, 2003, due to her alleged tampering with student grades. Respondent later filed a complaint for illegal dismissal, claiming violation of due process.
Labor Arbiter's Decision
The Labor Arbiter ruled in favor of the petitioner, affirming the legal validity of respondent's dismissal based on the evidence of grade tampering, concluding that serious misconduct warranted dismissal under Article 282 of the Labor Code. The Arbiter found her explanations concerning grade alterations unconvincing.
NLRC Rulings and CA Decision
Respondent appealed to the National Labor Relations Commission (NLRC), which initially acknowledged errors but later reversed its stance upon reconsideration, again affirming the legality of the dismissal. Subsequently, the Court of Appeals granted respondent's petition, declaring her dismissal illegal and awarding benefits without reinstatement.
Supreme Court's Review
Petitioner contested the CA's ruling, positing that the NLRC had acted within its jurisdiction and that procedural requirements regarding non-forum shopping had not been satisfactorily addressed by respondent. The Supreme Court reinstated the NLRC's decision, emphasizing the importance of adherence to procedural rules and affirming that respon
...continue readingCase Syllabus (G.R. No. 178837)
Case Background
- The case involves a petition for review on certiorari under Rule 45 of the Revised Rules of Court by the petitioner, Colegio de San Juan de Letran, against the respondent, Isidra Dela Rosa-Meris.
- The petition aims to review, reverse, and set aside the Decision of the Court of Appeals (CA) dated January 29, 2007, and its Resolution dated May 25, 2007, related to the case entitled Isidra Dela Rosa-Meris v. National Labor Relations Commission and others, docketed as CA-G.R. SP No. 92933.
Parties Involved
- Petitioner: Colegio de San Juan de Letran, a religious educational institution operated by the Order of Preachers.
- Respondent: Isidra Dela Rosa-Meris, who started her career at Letran as a probationary trial teacher in January 1971 and eventually became a Master Teacher in June 1982.
Timeline of Events
- 1971: Isidra Dela Rosa-Meris begins her employment as a probationary teacher.
- 1991: She resigns from her position.
- 1998: Returns to Letran as Junior Teacher C in the Elementary Department.
- 1999: Rehired as a substitute teacher until her termination on October 3, 2003.
Incident Leading to Termination
- September 10, 2003: Parents of students under Dela Rosa-Meris' class lodge complaints against her, alleging indifference and unprofessionalism.
- Investigation: Letran conducts an investigation and finds discrepancies between Dela Rosa-Meris' Dirty Record Book and Clean Record Book concerning students' grades.
- September 12, 2003: Dela Rosa-Meris is issued a letter detailing the complaints and discrepancies, allowing her 72 hours to explain.
Respondent's Defense
- Dela Rosa-Meris refu