Case Summary (G.R. No. 94523)
Background of Employment
Lilia G. Ariola was employed as a teacher from the school year 1954-55 until the school year 1975-76, serving continuously for 22 years before retiring on March 30, 1976. After a brief period working as an insurance underwriter, she was invited back in 1979 by the Mother Superior of St. Therestita's Academy, with the condition that she should be regarded as a regular teacher, a condition to which the school agreed. Ariola rejoined the school under a yearly renewable contract.
Disputes Over Compensation
Initially, Ariola and her co-teachers received summer living allowances for the school years 1979-1980 and 1980-1981. However, in June 1981, the school deducted this allowance from their salaries, leading to protests from the teachers. School administration meetings followed, where the legitimacy of the deductions was questioned, although the Mother Superior ultimately stated the financial inability to restore the allowances.
Termination of Employment
Due to ongoing disputes regarding compensation, a board meeting was held on January 19, 1983, which decided that no retired teachers would be rehired from the upcoming school year. After four years of satisfactory service upon her rehiring, Ariola was informed on March 1, 1983, that her contract would not be renewed. Subsequently, she filed a complaint for illegal dismissal with the NLRC on April 7, 1985, seeking reinstatement and backwages.
Labor Arbiter Decision
On August 14, 1987, the Labor Arbiter ruled in favor of Ariola, awarding her separation pay calculated at one-half month’s salary for each of her four years of service. This decision was subsequently appealed by the school to the NLRC.
NLRC Ruling
The NLRC upheld the Labor Arbiter’s decision with modifications, asserting that Ariola had become a "regular" employee based on her continuous service, and noted that the practice of issuing year-to-year contracts for rehired teachers violated her right to security of tenure. The NLRC stipulated that despite the contracts' fixed period, under Article 280 of the Labor Code and the Manual of Regulations for Private Schools, Ariola's employment could not be terminated without just cause.
Petition for Certiorari
In response to the NLRC's ruling, the petitioners filed a petition for certiorari, arguing that the decision contradicted prior Supreme Court rulings and that the nature of employment for rehired teachers could differ significantly from that of new hires facing probationary evaluations. They also contended that it was within their prerogative to adopt a policy against rehiring retired teachers.
Supreme Court’s Analysis
The Supreme Court assessed the records and concluded that the NLRC did not overstep its author
...continue readingCase Syllabus (G.R. No. 94523)
Case Overview
- This case addresses a petition for certiorari with an application for a preliminary injunction and/or restraining order to annul the resolution dated July 2, 1990, of the National Labor Relations Commission (NLRC).
- The decision being contested affirmed with modification the Labor Arbiter's ruling regarding the employment status and subsequent dismissal of Lilia G. Ariola, a former teacher at St. Therestita's Academy.
- The NLRC ordered the petitioner to pay Ariola back wages for three years, alongside separation pay.
Background of the Case
- Lilia G. Ariola had been employed as a school teacher from the school year 1954-55 up to 1975-76, totaling 22 years of continuous service.
- She retired on March 30, 1976, and received separation benefits amounting to P4,927.30.
- After a brief stint as an insurance underwriter, she was invited back to St. Therestita's Academy in 1979 under the condition of being a regular teacher.
- The conditions of her re-employment were accepted, and she signed a yearly renewable contract.
Issues of Pay and Employment Status
- During the school years 1979-1980 and 1980-1981, Ariola and her co-teachers received a summer living allowance, which was later deducted from their salaries.
- The school claimed the allowance had been mistakenly given, leading to protests from the teachers.
- A significant board