Case Summary (G.R. No. 252124)
Factual Antecedents
Mabao commenced her employment with BWS on June 7, 2007, achieving regular status by 2010. She served various roles until her suspension on September 22, 2016. The case involves Mabao's assertions of illegal suspension following discussions with school officials regarding her pregnancy. Conversely, petitioners claim that her suspension was necessary due to her violation of school policy based on moral grounds.
Mabao's Version of Events
On September 21, 2016, Mabao approached school officials to discuss her pregnancy. The following day, she was summoned and verbally suspended until she could present proof of marriage. On September 27, she received a formal notice of her indefinite suspension, which cited her premarital relationship as immoral conduct.
Petitioners' Account of Events
Petitioners allege that Mabao had confessed her pregnancy out of wedlock and that the suspension was mutually agreed upon as a temporary measure until her marriage. They have contended that Mabao was aware of the implications of her actions and that her suspension was therefore justified.
Labor Arbiter’s Ruling
The Labor Arbiter ruled in favor of Mabao, declaring her suspension as constructive dismissal and holding petitioners liable for back wages and other benefits. The decision was based on the premise that her suspension was unfounded and not supported by sufficient evidence.
NLRC Appeal Decision
The National Labor Relations Commission (NLRC) subsequently reversed the Labor Arbiter's ruling, asserting that there was no evidence to support claims of constructive dismissal and validating the suspension as permissible under school policies regarding moral conduct.
Court of Appeals Ruling
The Court of Appeals partially granted Mabao's petition for certiorari, agreeing with the NLRC that she was not constructively dismissed but declaring her suspension as illegal. The court reasoned that the grounds for suspension did not align with secular standards of morality, particularly since premarital sexual relations are not regarded as immoral in the broader societal context.
Legal Analysis on Morality Standards
The court emphasized that the relevant standard of morality pertains to public and secular ethics rather than religious morality. It noted that engaging in premarital sexual relations resulting in pregnancy does not constitute disgraceful or immoral conduct under secular laws. The court drew on precedents affirming that such actions are not punishable by law and do not breach fundamental state policies.
Procedural Due Process Considerations
The court held that petitioners failed to adhere to procedural due process, primarily the lack of an initial notice outlining the specific grounds for disciplinary action and not providing first opportunities for Mabao to be heard prior to her suspension. Given this failure, the court upheld the conclusion that her suspension was illegal.
Employment Status and Abandonment
While the court affirmed that there was no dismissal in the traditional sense, it determined that Mabao abandoned her employment following her refusal to return despite several notices. The court ruled that her intention to sever the employment relationship was evident through her commu
...continue readingCase Syllabus (G.R. No. 252124)
Case Background and Procedural Posture
- Petition for Review on Certiorari under Rule 45 of the Rules of Court was filed by Bohol Wisdom School (BWS), Dr. Simplicio Yap, Jr., and Raul H. Deloso (collectively BWS et al.) challenging the Decision and Resolution of the Court of Appeals (CA).
- The contested decision and resolution of the CA held BWS et al. liable for illegally suspending Miraflor Mabao.
- The case originated from Mabao’s complaint for illegal suspension and illegal dismissal filed before the National Labor Relations Commission (NLRC).
- Various tribunals' rulings were received: Labor Arbiter found Mabao constructively dismissed and awarded separation pay; NLRC reversed this, ruling no constructive dismissal but no illegal suspension; CA partially modified NLRC, declaring illegal suspension but no constructive dismissal.
Parties and Their Claims
- Miraflor Mabao was a regular grade school teacher at Bohol Wisdom School.
- Mabao filed complaint after she was suspended and refused to return to work following suspension for pregnancy out of wedlock.
- BWS et al. defended their actions as a management prerogative tied to morality standards of the Christian educational institution.
- Petitioners claimed suspension was agreed upon and complied with procedural due process substantially.
Facts as Presented by Mabao
- Mabao started employment on June 7, 2007, obtained regular status in 2010, and earned a monthly salary of PHP 20,860.00 excluding other benefits.
- Pregnancy was disclosed to principal and administrative head on September 21, 2016 before physical signs were evident.
- On September 22, 2016, Mabao was verbally suspended by Deloso without pay and was required to present proof of marriage to her boyfriend, the father of the child, as a condition to resume work.
- She was later served with a Disciplinary Form and a Letter confirming indefinite suspension without pay until she marries.
Facts as Presented by BWS et al.
- Mabao admitted pregnancy out of wedlock on September 19, 2016 and stated intention to marry soon.
- BWS convened and decided on suspension starting September 22 until Mabao got married to avoid questions from students and faculty.
- Mabao was reinstated only after producing proof of marriage on October 5, 2016, but she allegedly refused to return to work despite multiple notices.
- BWS denied any coercion to marry and asserted suspension was temporar