Case Summary (G.R. No. 56566)
Chronology of Events
Lolita Lao was appointed as a "non-tenured full-time probationary assistant professor C" with a salary of P13,000 per annum, as documented in a memorandum dated October 22, 1974. Despite being issued a contract for the following academic year at a salary of P15,155, this contract was never signed by the university president, which raised questions about its enforceability. Lao was informed by the university's officials in August 1975 that her services would be terminated at the end of the first semester, marking the conclusion of her probationary status.
Claims and Jurisdictional Issue
On October 3, 1975, Lao filed a petition seeking to restrain her termination and claiming damages totaling P99,000. The university's officials contended that there was no enforceable contract and that the case fell within the jurisdiction of the National Labor Relations Commission (NLRC). Following Lao’s termination on October 15, 1975, she amended her petition to focus solely on the damages claim.
Court's Findings
The lower court ruled in favor of Lao, determining that the university and its officials had violated her rights concerning the terms of her contract. The court awarded Lao P90,000 in moral and exemplary damages, referencing specific provisions of the Civil Code related to contracts and damages.
Appellate Court's Rulings
The Appellate Court upheld the lower court’s decision. The university and its officials subsequently appealed to the Supreme Court, arguing that the dispute fell under the jurisdiction of the NLRC due to the nature of employer-employee relations as outlined in the Labor Code.
Supreme Court's Analysis
The Supreme Court found that the NLRC did not have jurisdiction over the case. It determined that the existence of an employer-employee relationship between Lao and the university was undisputed, focusing on whether Lao transitioned from probationary to permanent employment. The Court concl
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Case Overview
- This case revolves around the jurisdiction of the Court of First Instance regarding Lolita U. Lao's claim for damages following her alleged malicious dismissal from her position as assistant professor at De La Salle University.
- The Appellate Court confirmed that Lao was appointed as a "non-tenured full-time probationary assistant professor C" with a salary of P13,000 per annum, effective October 16, 1974.
Employment History of Lolita U. Lao
- Lao was hired to strengthen the economics department and began her duties on October 16, 1974.
- In June 1975, she received a contract for the academic year 1975-76 with a salary of P15,155, which she signed, including her residence certificate details.
- The contract was not signed by the university president due to it not being forwarded by the chairman of the economics department, Frank Tajanan.
Notification of Termination
- In August 1975, Lao inquired about her contract and was informed by Tajanan of the intention to terminate her services at the end of the first semester, coinciding with her one-year probationary period.
- The dean of the college, Dr. Patricio R. Ceballos, confirmed the termination in a letter dated August 29, 1975, indicating the university's decision not to renew her contract.
- Brother Daniel Ortiz, the acting dean, reit