Case Summary (A.M. No. 1720, 1911, 2300-CFI)
Facts
• May 28, 2003: Sr. Quiambao directs petitioner to explain why she should not be dismissed for immoral conduct under the 1992 Manual of Regulations for Private Schools (1992 MRPS).
• May 31 & June 4–9, 2003: Petitioner, through counsel, denies any policy forbidding her conduct and insists her pregnancy is a private matter.
• June 11, 2003: SSCW terminates her employment citing “serious misconduct” and “disgraceful or immoral conduct” under Section 94(e) of the 1992 MRPS.
Procedural History
• February 28, 2006: Labor Arbiter upholds dismissal for immoral conduct.
• February 28 & May 21, 2007: NLRC affirms, applying Section 94(e) of the 1992 MRPS.
• September 24, 2008 & March 2, 2009: Court of Appeals denies certiorari, maintaining MRPS supremacy over the Labor Code.
• Petitioner elevates the dispute to the Supreme Court by Rule 45 petition.
Issues
1. Whether the 1992 MRPS, rather than the Labor Code, governs the termination of private school personnel.
2. Whether pregnancy out of wedlock constitutes “disgraceful or immoral conduct” under Section 94(e) of the 1992 MRPS.
Applicable Law
• 1987 Constitution: Guarantees security of tenure; public and secular morality standard.
• Labor Code Article 282: Just causes for dismissal; Articles 283–284: separation pay in specified cases.
• 1992 MRPS Section 94(e): Adds “disgraceful or immoral conduct” as a ground for terminating school personnel.
• Jurisprudence (Estrada v. Escritor; Anonymous v. Radam): Immorality must be measured by secular public order, not religious doctrine; consensual relations between unmarried adults without impediment are not punishable.
Applicability of the 1992 MRPS
The Supreme Court holds that:
• Sections 57, 69–70 of Batas Pambansa Blg. 232 expressly empower the Secretary of Education to prescribe implementing rules, including causes for termination.
• The 1992 MRPS, issued pursuant to BP 232, validly supplements the Labor Code for private schools.
• Petitioner’s belated challenge to the MRPS’s validity is barred by estoppel and lacks merit on the substance.
Validity of Dismissal
• Standard of Review: The Court may correct grave abuse of discretion—decisions unsupported by substantial evidence.
• Labor Tribunals’ Error: They deemed petitioner’s out-of-wedlock pregnancy inherently disgraceful or immoral based solely on her employment at a Catholic institution, without proof that her conduct harmed public or secular morality or caused actual scandal.
• Secular Morality Test: Under Estrada and Radam, immorality must be “detrimental to societal conditions” in secular terms. Unmarried adults conceiving without impediment do not violate public policy or secular norms.
• Burden of Proof: Employer must show by substantial evidence th
Case Syllabus (A.M. No. 1720, 1911, 2300-CFI)
Procedural History
- The petitioner, Cheryll Santos Leus, filed a complaint for illegal dismissal with the NLRC Regional Arbitration Branch after her termination by SSCW in June 2003.
- The Labor Arbiter dismissed her complaint on February 28, 2006, upholding her dismissal for “disgraceful or immoral conduct.”
- The NLRC affirmed that decision in Resolutions of February 28 and May 21, 2007.
- The petitioner elevated the case to the Court of Appeals via a Rule 65 petition for certiorari, which was denied in a Decision of September 24, 2008, and a Resolution of March 2, 2009.
- On January 28, 2015, the Supreme Court granted the petition for review on certiorari under Rule 45 and rendered the final judgment reversing and setting aside prior rulings.
Facts
- In May 2001, SSCW, a Catholic educational institution in Silang, Cavite, hired the petitioner as Assistant to the Director of the Lay Apostolate and Community Outreach Directorate.
- In 2003, the petitioner became pregnant out of wedlock; SSCW’s Directress, Sr. Edna Quiambao, advised her to resign, but the petitioner refused.
- SSCW formally charged her with serious misconduct and “disgraceful or immoral conduct” under the 1992 Manual of Regulations for Private Schools (MRPS).
- The petitioner submitted written explanations, through her own letters and counsel, denying the existence of any school policy prohibiting pregnancy out of wedlock and contending that her conduct did not constitute serious misconduct.
- SSCW maintained its position that Catholic doctrine justified dismissal and ultimately terminated her employment on June 11, 2003.
Issues
- Whether the 1992 MRPS, rather than the Labor Code, governs the termination of employment for non-teaching personnel of private schools.
- Whether the petitioner’s pregnancy out of wedlock constitutes a valid ground for dismissal under Section 94(e) of the 1992 MRPS, which provides for termination on account of “disgraceful or immoral conduct.”