G.R. No. 162053 - St. Luke's Medical Center Employees Association - AFW vs. National Labor Relations Commission

Case Summary (G.R. No. 162053)

Key Dates and Procedural History

• April 22, 1992 – Republic Act No. 7431 (Radiologic Technology Act) enacted.
• 1995–1998 – SLMC issues successive notices requiring Santos to obtain her PRC registration or face retirement/separation.
• November 26, 1998 – SLMC serves notice of separation effective December 30, 1998, following Santos’s failure to secure licensure or accept early retirement.
• March 2, 1999 – Santos files illegal dismissal complaint for reinstatement and back wages.
• September 5, 2000 – Labor Arbiter orders only separation pay (₱115,500).
• August 23, 2002 – NLRC affirms Labor Arbiter.
• January 29, 2004 – Court of Appeals affirms NLRC.
• March 7, 2007 – Supreme Court decision under the 1987 Constitution.

Applicable Law

• 1987 Philippine Constitution – Guarantees security of tenure (Art. XIII, Sec. 3).
• Republic Act No. 7431 – Requires certification from the Board of Radiologic Technology as prerequisite to practice.
• Police Power Doctrine – State may reasonably regulate professions in the interest of public health and safety.

Facts Leading to Separation

SLMC repeatedly notified Santos (March 4, 1997; May 14, 1997; March 13, 1998) to pass the June board examinations for radiologic technologists. Her continued employment without the required PRC license exposed SLMC to regulatory sanctions. In late 1998, SLMC offered her early retirement; upon her refusal, it formally separated her, citing lack of alternative vacancies compatible with her unlicensed status.

Union Intervention and SLMC’s Offer to Reassign

In September and December 1999, Santos’s union sought SLMC’s accommodation by assigning her to non-technical positions (e.g., CSS Aide, Dietary Secretary). SLMC maintained that any reassignment required compliance with ordinary recruitment rules and her qualification for the vacant post. It warned that failure to respond by specified deadlines would be deemed waiver of any re-employment opportunity.

Labor Arbiter and NLRC Findings

The Labor Arbiter awarded separation pay only, dismissing illegal dismissal and other monetary claims for lack of merit. The NLRC, in its August 23, 2002 decision, upheld that Santos’s failure to secure a certificate of registration constituted a valid statutory ground for termination. The CA affirmed these findings, referencing consistent factual findings and management prerogative.

Issues on Appeal

Whether the CA overlooked material facts concerning Santos’s right to security of tenure.
Whether SLMC’s termination violated constitutional and statutory labor protections.

Supreme Court’s Analysis on Just Cause

• Statutory Requirement – Under RA 7431, practicing radiologic technology without board registration is unlawful. Santos conceded her separation was solely due to failure to secure her certificate of registration.
• Constitutional Balance – While security of tenure is protected, it may be “reasonably regulated” under State police power for public health and safety. Licensing examinations are customary safeguards in health-related professions.
• Public Welfare – Unlicensed practice threatens patient safety and SLMC’s