Title
La Salette of Santiago, Inc. vs. National Labor Relations Commission
Case
G.R. No. 82918
Decision Date
Mar 11, 1991
Clarita Javier, a long-time teacher and administrator at La Salette schools, contested her reassignment after her fixed-term as High School Principal ended. The Supreme Court ruled her reassignment to teaching was lawful, affirming administrative roles are temporary and teachers’ tenure does not extend to such positions.
illegal dismissal
high school principal
security of tenure

Case Summary (G.R. No. 82918)

Factual Background

Clarita Javier had a long and continuous relationship with the La Salette School System in various capacities over some twenty years. She served successively as Principal of La Salette of Jones High School, Teacher and Subject Area Coordinator at La Salette of Santiago, full-time college instructor and Head of the Education and Liberal Arts Department at La Salette College, Assistant Principal of La Salette of Santiago (while retaining a part-time teaching assignment at La Salette College), and, for school years 1984-1985 and 1985-1986, High School Principal of La Salette of Santiago. The system’s practice fixed terms for principals at two years. On June 9, 1986, shortly after her principal term expired and before the next school year opened, the Board instructed her to report to La Salette College and named a replacement. Javier protested, refused the reassignment, and filed a complaint for illegal dismissal on June 18, 1986.

Trial and Administrative Proceedings

The Executive Labor Arbiter heard the complaint and, on January 26, 1987, ordered reinstatement of Javier to her former position as High School Principal, with full back wages of P15,637.50 and attorney’s fees of P1,563.75. The petitioner appealed to the National Labor Relations Commission. The Commission, by resolution of November 18, 1987, affirmed the Arbiter’s decision and denied reconsideration by resolution dated February 18, 1988. La Salette filed a petition for certiorari in the Supreme Court seeking annulment of the NLRC resolution.

Legal Issue

The central legal question was whether Clarita Javier had acquired security of tenure as High School Principal in addition to her security of tenure as a faculty member; alternatively, whether the nonrenewal or reassignment effected by the School constituted illegal dismissal. A subsidiary question was whether the NLRC committed grave abuse of discretion in reinstating Javier to the administrative post.

Parties’ Contentions

La Salette of Santiago, Inc. maintained that administrative posts such as high school principal are normally held for fixed terms or at the pleasure of the school and do not confer a separate or additional tenure distinct from faculty tenure unless expressly agreed or provided by law. The petitioner invoked managerial prerogative to transfer or reassign personnel. Clarita Javier contended that the Board’s removal from the post and assignment to college teaching amounted to an unlawful termination of her principalship and therefore an illegal dismissal. The NLRC relied on the asserted distress and prejudice to Javier’s working conditions in upholding the Arbiter.

Applicable Law and Precedent

The Court reiterated the standards articulated in University of Santo Tomas (en banc): a teacher acquires permanent employment or security of tenure only upon meeting three requisites — being a full-time teacher, rendering three consecutive years of service, and having that service adjudged satisfactory. The Manual defines a “full-time teacher,” prescribes the three-year rule (par. 75), and sets normal teaching loads (pars. 77 and 78). The Court also relied on Brent School, Inc. v. Zamora and related authorities construing Article 280 of the Labor Code to allow fixed-term employment where the parties knowingly and voluntarily agreed to it, absent coercion or circumvention of tenure protections. Section 108 of the Corporation Code was noted to illustrate customary fixed terms for corporate directors and officers in educational corporations.

Court’s Reasoning

The Court found, on the record, that Javier had indisputably acquired security of tenure as a faculty member, having served full-time for well beyond the three consecutive years and having been repeatedly retained and assigned to teaching and administrative duties for two decades. The Court distinguished faculty tenure from tenure in administrative posts. It observed that Javier’s administrative assignments — including principals hip, subject area coordinator, department head and assistant principal — were of a non-permanent character, held for fixed periods or at the pleasure of the school, and formed a recognized pattern in the La Salette School System. The Court emphasized that Javier had manifested awareness of that pattern and had accepted certain assignments with explicit reservations and with continued part-time teaching at La Salette College. There was no evidence that she had been coerced into accepting administrative posts or that she reasonably believed those posts conferred a second, permanent tenure. The Court thus concluded that expiration of an administrative term did not extinguish tenure as a faculty member and that Javier had not acquired permanency as High School Principal.

Evaluation of the NLRC’s Decision

The Court analyzed the NLRC’s reasoning that the transfer subjected Javier to inhuman treatment and prejudiced her right to good and human working conditions. The Court found that claim unsupported by the facts. The notification of the expiration of Javier’s term and the adviso

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