Case Summary (G.R. No. 122955)
Background Facts
Adoracion Roxas hired Esther Reyes on a contract basis, initially from June 1, 1991, to March 31, 1992. Reyes commenced work earlier, on May 2, 1991. During her employment, she took approved leave due to illness but was unable to return to her position due to perceived replacement. On March 25, 1992, Roxas sent Reyes a termination letter indicating that her contract would not be renewed. This letter followed Reyes's filing of a complaint against Roxas and St. Theresa's School, claiming unfair labor practices and illegal dismissal.
Series of Proceedings
On November 12, 1993, the Labor Arbiter ruled in favor of Reyes, declaring her dismissal illegal and ordering her reinstatement with backwages and damages. The petitioners appealed this decision to the NLRC on December 7, 1993. Interim to the appeal, Reyes sought immediate execution of the reinstatement order, but her motions remained unresolved due to staff changes within the NLRC. Eventually, the NLRC sided with the petitioners on November 29, 1994, declaring Reyes's separation from service legal, but also ordering the payment of backwages from the time of dismissal until the NLRC's decision.
Award of Backwages
This case presents a crucial point regarding the appropriateness of backwages when dealing with a legally validated dismissal. Backwages are typically awarded as a remedy for illegal terminations. However, the Court recognized that since Reyes's dismissal had been deemed valid and lawful, the previous ruling granting her backwages contradicted legal principles and established jurisprudence.
Legal Rationale
The Court highlighted that contracts of employment, including those with fixed terms, must be adhered to if entered into voluntarily and are compliant with public policy. Although Reyes's contract stipulated a fixed duration, the nature of her duties did not prohibit such an agreement under Article 280 of the Labor Code. Furthermore, the special requirements for permanent employment of private teachers necessitate satisfactory se
...continue readingCase Syllabus (G.R. No. 122955)
Case Background
- The case was decided by the Supreme Court on April 15, 1998, under G.R. No. 122955.
- The petitioners are St. Theresa's School of Novaliches Foundation and Adoracion Roxas, the school's president.
- The respondents include the National Labor Relations Commission (NLRC) and Esther Reyes, a private respondent.
- The case revolves around the validity of Esther Reyes's dismissal and the subsequent award of backwages by the NLRC.
Legal Principles
- The principle of justice is emphasized, stating that it should not be denied to any party.
- The law protects employee rights but does not permit the oppression of employers.
- The dispute is centered on the NLRC's resolution that awarded backwages despite a finding that Reyes's dismissal was valid.
Employment Details
- Esther Reyes was hired on a contract from June 1, 1991, to March 31, 1992, although she started working earlier on May 2, 1991.
- Reyes took approved leaves due to illness in February 1992, returning to work briefly on March 2, 1992.
- Following her brief return, Reyes did not report back to work, which the petitioners claimed was due to abandonment.
- Conversely, Reyes contended that she was replaced