Case Summary (G.R. No. 152777)
Summary of Employment History
Petitioner Lacuesta was initially engaged as a part-time lecturer at Ateneo during the school years 1988-1989 and 1989-1990. Subsequently, she was appointed as a full-time instructor on probation on July 13, 1990, with her contract renewed for three consecutive years intermittently. She received a notice on January 27, 1993, that her contract would not be renewed due to perceived incompatibility with other department faculty. Petitioner later accepted an alternative role as an editor with the University Press.
Legal Proceedings
On December 23, 1996, Lacuesta filed a complaint for illegal dismissal, seeking reinstatement and damages. The Labor Arbiter ruled in her favor, ordering reinstatement, but this decision was reversed by the National Labor Relations Commission (NLRC), which found valid Lacuesta's quitclaim that she signed prior to the complaint. The Court of Appeals upheld this reversal, leading to Lacuesta's further appeal.
Core Legal Issues
Lacuesta challenged the Court of Appeals’ reliance on the Manual of Regulations for Private Schools, asserting that the Labor Code—not the Manual—should determine the criteria for permanent employment. She maintained she had achieved regular employment status after rendering significant service and argued that her quitclaim was coerced.
Respondent’s Defense
Respondents contended that the Manual of Regulations governs permanent employment, emphasizing that full-time faculty members require three consecutive satisfactory years of service to attain regular status. They argued that Lacuesta was merely on probation and that her contract expired rather than constituting illegal dismissal.
Court’s Analysis and Ruling
The Court ruled that the Manual of Regulations for Private Schools, not the Labor Code, determines faculty members' employment status in educational institutions. The Court affirmed that part-time employment does not
...continue readingCase Syllabus (G.R. No. 152777)
Case Background
- This case involves a petition for review on certiorari filed by petitioner Lolita R. Lacuesta against Ateneo de Manila University and its officials, Dr. Leovino Ma. Garcia and Dr. Marijo Ruiz.
- The petition challenges the Decision dated October 12, 2001, of the Court of Appeals and its Resolution dated February 21, 2002, which denied the motion for reconsideration.
- The appellate court upheld the decision of the National Labor Relations Commission (NLRC) dated February 24, 2000, which reversed the Labor Arbiter's ruling.
Employment History of Petitioner
- Petitioner was initially hired as a part-time lecturer in the English Department on a contractual basis for the second semester of the school year 1988-1989.
- She was re-hired for the first and second semesters of the school year 1989-1990.
- On July 13, 1990, she was appointed as a full-time instructor on probation, with her contract effective from June 1, 1990, to March 31, 1991.
- Her probationary contract was subsequently renewed two more times, lasting until March 31, 1993.
Termination and Subsequent Events
- On January 27, 1993, Dr. Leovino Ma. Garcia informed Lacuesta that her contract would not be renewed due to her inability to integrate well with the English Department.
- Fr. Joaquin Bernas, S.J., the university president, clarified in a February 11, 1993 letter that Lacuesta was not being terminated; her contract was simply expiring.
- Fr. Bernas offered her an alternati