Case Summary (G.R. No. 223665)
Key Individuals and Context
Petitioner: University of the Cordilleras (including its President, Vice Presidents, Dean of the College of Teacher Education)
Respondent: Benedicto F. Lacanaria, Instructor–Associate Professor, College of Teacher Education
Context: Respondent was dismissed for alleged serious misconduct toward a student during a class activity.
Key Dates
• June 2005 – Lacanaria hired as Instructor–Associate Professor
• February 25, 2010 – Classroom incident involving student Rafael Flores
• March–June 2010 – University grievance proceedings, termination notice, motion for reconsideration
• June 9, 2010 – Labor complaint filed by Lacanaria
• December 30, 2010 – ELA dismisses complaint (except 13th-month pay)
• October 21, 2011 & January 10, 2012 – NLRC resolutions affirm dismissal
• March 18, 2016 – CA reverses NLRC and orders reinstatement with damages
• September 27, 2021 – SC decision under review (1987 Constitution applies)
Applicable Law
• 1987 Philippine Constitution (security of tenure)
• Labor Code (Articles 294, 297 renumbered) – just and authorized causes for termination; procedural due process (two-notice rule)
• Omnibus Rules Implementing the Labor Code – standards of due process
• University Faculty Manual – grievance procedure and code of conduct
• Manual of Regulations for Private Higher Education – causes for terminating employment
Facts
During a student presentation, Flores, who suffered a persistent cough, collapsed during a dance segment. Lacanaria reportedly (a) forced Flores to dance despite illness, (b) ignored his collapse, (c) made disparaging remarks (“umupo ka muna diyan, hindi ka pa naman mamamatay” and later “tae mo!”), and (d) delayed or denied his clinic request. Flores filed complaints; classmates corroborated via affidavits and video.
Procedural History
- University issued a Charge Sheet (serious misconduct, ethics violation) without specifying hearing date/time/place.
- Lacanaria filed Answer and intended resignation (later withdrawn).
- Grievance Committee hearings (March 30 & April 7, 2010) proceeded despite his non-attendance; recommendation to dismiss.
- Notice of Decision dated May 15, 2010 (signed by VP for Administration) – effective dismissal.
- Motion for Reconsideration denied by the President on June 24, 2010.
- Lacanaria filed illegal dismissal complaint before DOLE.
- ELA dismissed complaint (December 30, 2010) but awarded 13th-month pay.
- NLRC affirmed (October 21, 2011; denied reconsideration January 10, 2012).
- CA reversed NLRC (March 18, 2016), ruling dismissal unjust, ordering reinstatement, backwages, moral/exemplary damages, attorney’s fees.
- University filed Rule 45 petition before SC.
Issues
A. Whether substantial evidence supported dismissal for serious misconduct and conduct unbecoming of an academician.
B. Whether procedural defects (notice of hearing/specifics, signatory of termination notice) tainted dismissal.
C. Whether respondent was entitled to reinstatement and damages.
Substantive Due Process: Just Cause
Under Article 297 of the Labor Code, serious misconduct must be grave, work-related, and wrongful in intent. Lacanaria’s actions—ignoring a sick student’s collapse, using insulting language, preventing aid, and minimizing medical needs—demonstrated aggravated misconduct directly tied to his teaching duties and wrongful intent, rendering him unfit to continue in his role. The University Faculty Manual and higher-education regulations require respect, dignity, and care for students; those standards were breached.
Totality of Infractions
The “totality of infractions” rule permits consideration of prior misconduct in assessing penalty. Lacanaria had been verbally and officially warned for “green jokes.” His pattern of disrespect toward students, coupled with the 2010 incident, justified dismissal under management prerogative to protect institutional interests.
Procedural Due Process Lapses
Although the University substantially complied with due process by issuing Charge Sheet and allowing written defenses, it failed to:
• Specify date, time, and place in the initial notice (five-day requirement under Faculty Manual)
• Prove actual receipt of notice for the March 30 hearing; notice for April 7 hearing arrived same day, precluding preparation
• Ensure a formal hearing or meaningful alternative before concluding investigation
• Have the President, as required by Faculty Manual, sign the May 15 termination not
Case Syllabus (G.R. No. 223665)
Facts
- In June 2005, the University of the Cordilleras employed respondent Benedicto F. Lacanaria as an Instructor–Associate Professor in the College of Teacher Education.
- On February 25, 2010, student Rafael Flores collapsed during a class presentation after coughing; Lacanaria allegedly ignored his condition, compelled him to dance, and dismissed his request to seek medical attention.
- Flores was later diagnosed with costochondritis and an upper respiratory tract infection at Notre Dame Hospital.
- Upon Flores’s return, Lacanaria reportedly uttered “tae mo!” and displayed callous remarks to the class.
- Flores filed a complaint with affidavits from classmates; the University issued a Charge Sheet for serious misconduct and Code of Ethics violations.
Procedural History
- Grievance Committee hearings were scheduled March 30 and April 7, 2010; Lacanaria failed to appear due to alleged lack of timely notice.
- The Committee’s undated Report and Recommendation advised dismissal; the Vice President for Administration issued a Notice of Decision on May 15, 2010, dismissing Lacanaria effective that date.
- Lacanaria moved for reconsideration and withdrew, then retracted, his resignation letter; his motion was denied by the University President on June 24, 2010.
- Lacanaria filed an illegal dismissal complaint with the Department of Labor and Employment, then appealed the Executive Labor Arbiter’s (ELA) dismissal of his complaint (except 13th-month pay) to the NLRC.
- The NLRC affirmed; Lacanaria appealed to the Court of Appeals (CA). The CA reversed, finding invalid dismissal and procedural defects, and ordered reinstatement with backwages, moral and exemplary damages, and attorneys’ fees.
- Petitioners filed a Rule 45 petition before the Supreme Court raising questions of law.
Issues
- Whether there was substantial evidence to support dismissal for serious misconduct and conduct unbecoming of an academician.
- Whether procedural due process under the Faculty Manual and Labor Code was observed in the investigation and dismissal.
- Whether Lacanaria is entitled to reinstatement, damages, and attorneys’ fees given the nature of his dismissal.
Ruling of the Executive Labor Arbiter and NLRC
- The ELA (Dec. 30, 2010) held Lacanaria’s conduct—forcing a sick student to perform, ignoring his collapse, and using disparaging language—constituted serious misconduct justifying dismissal.
- The ELA found due process was observed: notice of charges, submission of answer, hearings (waived by non-appearance), and notice of termination.
- The ELA awarded only the 13th-month pay.
- The NLRC (Oct. 21, 2011; Jan. 10,