Case Summary (G.R. No. 117514)
Facts of the Case
Mrs. Normita A. BaAez was engaged by Mt. Carmel College as a probationary teacher under a written employment contract effective June 1, 1989. The contract outlined her monthly salary of P1,675.00 and specified that her employment would last from the academic year (SY) 1989-1990 until SY 1991-1992, with the stipulation that her employment could be terminated at any time if she failed to meet the conditions set by the school. In March 1992, the school terminated Mrs. BaAez's employment after she did not pass the National Teachers Board Examination.
Labor Arbiter's Decision
Following her termination, Mrs. BaAez filed a complaint for illegal dismissal. The Labor Arbiter ruled in her favor, finding that her dismissal was illegal, and ordered her reinstatement along with full back wages.
NLRC Appeal and Findings
The decision of the Labor Arbiter was appealed to the National Labor Relations Commission (NLRC), which reversed the earlier ruling, concluding that Mrs. BaAez’s dismissal was, in fact, legal. However, the NLRC ordered the school to pay her P10,200.00, corresponding to her salary for the unexpired portion of her probationary period, calculating that her probation would have concluded in June 1992, three months after her termination.
Issue for Resolution
The petitioners sought to contest the NLRC's ruling, specifically questioning whether the NLRC had gravely abused its discretion by determining there existed an "unexpired portion" of Mrs. BaAez's probationary contract, which they argued expired at the end of the school year 1991-1992.
Legal Interpretation of Contract Duration
Upon review, the Supreme Court determined that the interpretation of the contract was clear. The contract explicitly stated that Mrs. BaAez's employment, established by the school year calendar, ran from June to March of each academic year. The academic year typically comprises ten months, differing from a calendar year of twelve months. This delineation is critical to understanding the timeline of her employment.
Precedents Considered
The Court referenced previous cases, notably Espiritu Santo Parochial School v. NLRC and Colegio San Agustin v. NLRC, to highlight the distinction between a school year and a calendar year. Those rulings underscored that probationary periods described in academic terms cannot be equated to calendar years, thereby affirming the un
...continue readingCase Syllabus (G.R. No. 117514)
Case Citation
- Court: Supreme Court of the Philippines
- Division: Second Division
- G.R. No.: 117514
- Date: October 04, 1996
- Reporter: 331 Phil. 254
Parties Involved
Petitioners:
- Mt. Carmel College
- Bishop Julio Labayen (President)
- Sister Mercedes Salud (Vice President)
Respondents:
- National Labor Relations Commission (NLRC)
- Mrs. Normita A. BaAez (Private Respondent)
Background of the Case
- The case revolves around a dispute regarding the termination of Mrs. Normita A. BaAez, who was employed as a grade school teacher by Mt. Carmel College under a written Contract of Probationary Employment.
- The employment contract specified a monthly salary of P1,675.00 and stipulated the duration of employment from the school year 1989-1990 to the school year 1991-1992.
- The contract allowed for termination at any point if the employee failed to meet the conditions set by the school and stated that the school had no further liability, including separation pay.
Facts of the Case
- Employment Commencement: June 1, 1989
- Termination of Employment: March 1992, due to Mrs. BaAez's failure to pass the National Teacher's Board Examination.
- Complaint Filed: Following her termination, Mrs. BaAez filed a complaint for illegal dismissal.
- Labor Arbiter's Decision: The Labor Arbiter ruled in favor of Mrs. BaAez, finding her dismissal illegal and ordering reinstatement with full back wages.
- NLRC's Ruling: Upon appeal, the NLRC reversed the Labor Arbiter