Case Summary (G.R. No. 107590)
Complaint and Termination Notices
On April 24, 1990, the complainants received uniform notices informing them of the expiration of their temporary appointments as instructors at PLM, effective May 31, 1990, indicating a non-renewal for the 1990-1991 school year. These instructors, who were part of the PLMFO, submitted complaints to the CSC stating they were illegally dismissed and faced unfair labor practices following their termination notices.
Filing of Complaints and PLM’s Defense
In their complaint filed on May 29, 1990, the instructors alleged illegal dismissal and unfair labor practices. In response, PLM denied the allegations, asserting the temporary nature of the instructors' contracts and suggesting that non-renewal was justified based on performance or recommendations from their respective Deans.
PSC’s Initial Ruling
The Civil Service Commission (CSC) referred the case to the Public Sector Labor-Management Council (PSLMC), which, after due process, ruled on December 16, 1991, that PLM committed unfair labor practices. The PSLMC ordered the reinstatement of the instructors, asserting that the termination was aimed at suppressing their union activities.
Further Proceedings and CSC’s Affirmation
Following the PSLMC's ruling, PLM's requests for reconsideration were denied. The CSC, upon review, concluded that the termination of the instructors was illegal and directed PLM to reinstate them with back salaries. PLM’s appeals for reconsideration were similarly rejected.
Legal Arguments by PLM
In its petition for certiorari, PLM argued that the CSC acted with grave abuse of discretion by adopting the PSLMC's findings and orders without allowing PLM to introduce evidence or present a defense against the allegations of unfair labor practice and illegal dismissal.
Court’s Consideration of Due Process
The Supreme Court noted the interlinking of the allegations of unfair labor practices with the issue of illegal dismissal. It recognized that even temporary employees possess rights to self-organization and cannot be dismissed solely based on their union membership. However, it also underscored that PLM failed to substantiate its claims against the instructors adequately.
Findings on Performance Evaluations and Union Suppression
The PSLMC and CSC concluded that PLM's reasons for the non-renewal of the instructors' contracts were spurious or unsupported by evidence. PLM's failure to produce necessary documents for its defense impli
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Case Background
- The petition arose from a complaint for illegal dismissal and unfair labor practices filed by private respondents against PLM and its officers.
- The private respondents were sixteen (16) full-time instructors at PLM who were employed under "temporary contracts" renewable annually.
- All respondents were members of the Pamantasan ng Lungsod ng Maynila Faculty Organization (PLMFO).
- On April 24, 1990, uniform termination notices were sent to the private respondents regarding the expiration of their temporary appointments on May 31, 1990, and the non-renewal for the 1990-1991 school year.
Procedural History
- Following the termination notices, private respondents filed a verified complaint with the CSC on May 29, 1990, alleging illegal dismissal and unfair labor practice.
- PLM responded by denying the claims and arguing the temporary nature of the respondents' contracts justified their non-renewal.
- The CSC referred the case to the Public Sector Labor-Management Council (PSLMC) for resolution.
- The PSLMC conducted hearings and found PLM guilty of unfair labor practices, ordering the reinstatement of the complainants.
PSLMC Findings and Resolutions
- On December 16, 1991, the PSLMC issued a Resolution declaring PLM's actions as unfair labor practices, emphasizing the complainants' ri