Case Summary (G.R. No. L-3546)
Facts of the Case
The teachers were hired by Espiritu Santo Parochial School on June 1, 1984, under probationary contracts, which were expected to be renewed annually. Their services were terminated between April 1 and 15, 1985. In response to their dismissal, the teachers filed charges of unfair labor practice and illegal dismissal against the school on May 8, 1985. The labor arbiter ruled in favor of the teachers, declaring the school guilty of unfair labor practice, ordering their reinstatement with backwages, awards for attorney’s fees, and dismissing the claim for damages due to insufficient evidence.
Developments in the Labor Arbiter and NLRC
The school appealed the labor arbiter's ruling to the NLRC. The NLRC upheld the labor arbiter's decision on February 29, 1988, except for the charge of unfair labor practice, which was dismissed. The core issues presented by the school in their appeal include the argument that the contracts of the teachers had simply expired and were not renewed, asserting that the termination was not an act of dismissal but rather an expiration of contract.
Legal Framework and Arguments
The school contended that under Article 282 of the Labor Code, the contracts of probationary employment could be structured on a school-year basis. The petitioners asserted that the teachers did not meet the necessary standards for permanent employment and claimed that there could be no unfair labor practice since the termination was orchestrated by head teachers who were also leaders of the union.
Conversely, the teachers asserted that during the probationary period outlined in the Manual of Regulations for Private Schools, they could only be dismissed for just cause and raised the contention that their termination, occurring within less than a year of employment, was therefore illegal.
Court’s Analysis of Dismissal and Labor Practice
The Court found that the individual teachers were indeed considered probationary employees based on the relevant regulations, which extended the probationary period for teachers up to three years. However, the Court noted that dismissal could only occur for valid justifiable reasons. There was insufficient evidence to suggest that the teachers were terminated for a just cause, especially given their positive performance ratings that ranged from 85% to 90%. The Court articulated that the lack of valid grounds surrounding their dismissal rendered it void.
Ruling on Additional Contentions
Regarding the petitioners' claims of no anti-union bias due to the involvement of union leaders in the termination process, the Court clarified that the absence of anti-union bias does not negate the obligation to demonstrate lawful justification for termination. The Court reiterated the importance that the dismis
...continue readingCase Syllabus (G.R. No. L-3546)
Case Citation
- G.R. No. 82325
- September 26, 1989
- 258 Phil. 600, SECOND DIVISION
Overview of the Case
- This case revolves around a petition for certiorari filed against the National Labor Relations Commission (NLRC) regarding the illegal dismissal of seven individual teachers by the Espiritu Santo Parochial School.
- The petitioners are the school and its administrators, while the respondents include the dismissed teachers and their faculty association.
Background Facts
- The seven individual private respondents were employed by the petitioner-school on a probationary basis starting June 1, 1984.
- Their employment was terminated between April 1 and April 15, 1985.
- On May 8, 1985, the teachers filed a complaint against the school for unfair labor practices and illegal dismissal, seeking damages.
Labor Arbiter's Ruling
- The labor arbiter found the petitioners guilty of unfair labor practices and ordered:
- Reinstatement of the teachers with full back wages from the start of the school year 1985-1986 until actual reinstatement.
- Payment of attorney's fees equivalent to 10% of the total award.
- Dismissal of the claim for damages due to insufficient evidence.
NLRC Decision
- The NLRC affirmed the labor arbiter's decision on February 29, 1988, but dismissed the charge of unfair labor practice for lack of evidence.
Issues Raised by Petitioners
- The petitioners contended that:
- The teachers were not dismissed; their contracts simply expired and were not renewed.
- Contracts were schoolyear-based and expired automatically unless renewed.
- They were entitled to a longer pr