Title
St. Joseph Academy of Valenzuela Faculty Association vs. St. Joseph Academy of Valenzuela
Case
G.R. No. 182957
Decision Date
Jun 13, 2013
Non-licensed teachers dismissed for lacking qualifications; SC denied reinstatement and backwages but granted financial assistance based on equity and years of service.
termination
reinstatement
financial assistance

Case Summary (G.R. No. 182957)

Factual Background: Strike Notice, Voluntary Arbitration, and Teacher Qualifications

The petitioner initiated the dispute by filing a notice of strike against SJAV, alleging illegal termination and union busting. After the parties agreed to submit the controversy for voluntary arbitration, the SOLE took cognizance of the case.

Initially, nineteen (19) union members were affected. For the four licensees who had passed the board examinations, the SOLE ordered reinstatement with full backwages computed up to the date of their actual reinstatement. For the remaining fifteen non-licensees, the SOLE differentiated among those holding relevant permits. It ordered reinstatement only for those who had submitted a valid temporary or special permit, granting full backwages computed from the time their compensation was withheld until their actual reinstatement. However, it also limited their continued service to the remaining period corresponding to the validity of their permits.

The SOLE Decision: Reinstatement and Backwages Despite Probationary Status

In ordering reinstatement and backwages for the qualifying non-licensees, the SOLE reasoned that even if they were probationary employees, they still enjoyed security of tenure, and SJAV should have given them the opportunity to comply with the licensure requirement mandated by R.A. No. 7836. On that basis, the SOLE ruled that SJAV should retain their services and pay backwages from April 1, 2003 up to the date they were reinstated to their former positions, subject to the period limitation aligned with permit validity.

CA Ruling: Reinstatement No Longer Possible; Backwages Deleted

On CA review, the CA deleted the reinstatement and backwages portions of the SOLE decision. The CA ruled that reinstatement was no longer possible because it was the Department of Education, Culture and Sports that could assign para-teachers to schools as it determined. The CA also emphasized that SJAV could not be deprived of its right to choose its teachers and that the positions had already been filled.

The CA further deleted the award of backwages. It relied on the SOLE’s own factual and legal conclusion that SJAV had not committed illegal dismissal. The CA characterized the non-licensees as not being regular employees, and because there was no illegal dismissal, backwages could not stand.

Issues Raised on Review and the Parties’ Positions

Before the Supreme Court, the petitioner sought partial restoration of the SOLE’s financial awards. It asked for reinstatement of the backwages and, in the alternative, for separation pay in lieu of reinstatement, anchored on equity and compassionate justice. The petitioner candidly acknowledged that the temporary or special permits of the non-licensees had already expired, thereby making reinstatement impossible.

The petitioner’s equitable plea emphasized the non-licensees’ years of service, their alleged contributions to the school’s progress, and their claimed efficiency as teachers. The petitioner also informed the Court that two non-licensees, Eliseef and Musa, pursued a separate claim before the National Labor Relations Commission, which resulted in a Labor Arbiter ruling in 2005 that recommended that the federation file a supplemental pleading on complainants’ benefits.

SJAV, for its part, urged dismissal of the petition. It argued that since non-licensees could not become regular employees, there could be no award of reinstatement or backwages, which would presuppose illegal termination.

Governing Standard: Rule 45 Review and the “grave abuse” Lens

The Court reiterated the basic approach for reviewing CA decisions in labor cases under Rule 45. It stressed that in such a review, the Court does not directly reassess the labor tribunal’s merits as in an appeal. Instead, the Court reviews legal correctness, asking whether the CA correctly determined whether the labor tribunal committed grave abuse of discretion. The Court explained that the CA, in effecting Rule 65 review of the labor decision, applied the grave abuse framework rather than an appellate standard. Thus, the Supreme Court’s inquiry was limited to whether the CA erred in deleting the SOLE awards on the legal question of whether the labor tribunal’s ruling involved grave abuse.

Reinstatement and Backwages: Illegal Dismissal as the Fundamental Predicate

The Court restated the general rule that a finding of illegal dismissal entitles an employee to the twin remedies of reinstatement and full backwages, as reflected in Article 279 of the Labor Code. It explained the purpose of backwages: the law intends that backwages accumulate from the date of illegal dismissal until actual reinstatement. It also recognized that if reinstatement becomes impossible, backwages may be computed only up to the date the decision becomes final.

Critically, the Court tied the entitlement to backwages to the existence of illegal dismissal. It held that reinstatement and payment of backwages are proper only in cases of illegal dismissal.

No Illegal Dismissal Under R.A. No. 7836; Qualification Incompatibility Bars Reinstatement

The Court agreed that the SOLE and the CA were “one in ruling” that SJAV had not committed illegal dismissal against the non-licensees. The Court grounded this agreement on the statutory qualification requirements under R.A. No. 7836, which provides that no person shall engage in teaching and/or act as a professional teacher unless duly registered and licensed, or unless holding a valid special/temporary permit.

Because the non-licensees lacked the necessary qualification to be engaged in teaching and/or act as professional teachers, the Court ruled that reinstatement was not possible. It emphasized that this conclusion was binding given the absence of any circumstance that would undermine the findings and conclusions of the SOLE and the CA. The Court invoked the general rule that factual findings of the SOLE and the CA, and their conclusions drawn therefrom, are binding when supported by evidence.

Consequently, the Court held that the CA did not err in ruling that reinstatement could no longer be ordered.

Deletion of Backwages: Consistent With the Absence of Illegal Dismissal

In the same manner, the Court held that the CA did not commit reversible error in deleting the backwages. It reasoned that backwages and other monetary benefits are justified only when there is illegal dismissal. Since the legal and factual conclusion was that SJAV did not commit illegal dismissal, the premise for backwages was absent. On that basis, reinstatement’s impossibility did not become the controlling ground, because the decisive deficiency was the lack of illegal dismissal as a legal predicate for the backwages award.

Equitable Relief: Financial Assistance in Exceptional Cases

Even with the rejection of backwages as a legal consequence, the Court recognized that in exceptional cases, it had granted financial assistance to employees who were legally dismissed, as a measure of social justice or based on equity, provided the dismissal was not grounded on serious misconduct, did not reflect on the employee’s moral character, and did not involve moral turpitude.

The Court relied on prior rulings such as Nissan Motor Philippines, Inc. v. Angelo, which acknowledged awards of financial assistance when circumstances warranted compassionate and social justice relief. It also cited Pharmacia and Upjohn, Inc. v. Albayda, Jr., which treated financial assistance, equivalent to one-half (one-half) months pay for every year of service, as equitable. The Court noted that in Pharmacia, while the employee’s actions were a valid ground for termination, the conduct was not so reprehensible as to warrant total disregard of the employee’s long service.

Application to the Non-Licensees: License Failure Without Moral Turpitude

The Court applied these equity principles to the thirteen non-licensees (excluding Eliseef and Musa). It characterized their dismissal as due to failure to possess teaching licenses. The Court found that the dismissal was not due to serious

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