Case Digest: St. Paul College v. Ancheta II
G.R. No. 169905 : September 7, 2011
ST. PAUL COLLEGE QUEZON CITY, SR. LILIA THERESE TOLENTINO, SPC, SR. BERNADETTE RACADIO, SPC, and SR. SARAH MANAPOL, Petitioners, v. REMIGIO MICHAEL A. ANCHETA II and CYNTHIA A. ANCHETA, Respondent.
PERALTA, J.:
FACTS:
Remigio Michael was hired by the St. Paul College (SPCQC) as a teacher in the Gen. Education Dept. with a probationary rank in SY 1996-1997 which was renewed the following year. His wife, Cynthia was was also hired as a part time teacher of the Mass Comm Dept in the 2nd Sem SY 1996-1997 and her appointment was renewed for SY 1997-1998. February 1998, the spouses both wrote a letter addressed to Sr. Lilia asking for their contract to be renewed which was indeed granted by the College Council as evidenced by a letter sent by petitioner.
April 22,1998, a letter, whose signatures includes that of the respondents, was sent to Sr. Bernadette. The said letter contain teachers sentiments regarding school policies. However, April 21, 1998, a letter written by the latter was shown, reiterating the conversation of Sr. Bernadette and Remigio regarding the non compliance of respondent to instructional school policies. Accordingly, Sr. Bernadette wrote a letter endorsing the termination of the spouses. Respondents submitted their comments however they were still terminated and their letter for reconsideration denied thus the filling of a complaint for illegal dismissal which was dismissed by both NLRC and LA but was granted by the CA. Petitioners MR was denied hence the present petition.
ISSUE: Whether or not the spouses were illegally dismissed.
HELD:.
LABOR LAW
ST. PAUL COLLEGE QUEZON CITY, SR. LILIA THERESE TOLENTINO, SPC, SR. BERNADETTE RACADIO, SPC, and SR. SARAH MANAPOL, Petitioners, v. REMIGIO MICHAEL A. ANCHETA II and CYNTHIA A. ANCHETA, Respondent.
PERALTA, J.:
FACTS:
Remigio Michael was hired by the St. Paul College (SPCQC) as a teacher in the Gen. Education Dept. with a probationary rank in SY 1996-1997 which was renewed the following year. His wife, Cynthia was was also hired as a part time teacher of the Mass Comm Dept in the 2nd Sem SY 1996-1997 and her appointment was renewed for SY 1997-1998. February 1998, the spouses both wrote a letter addressed to Sr. Lilia asking for their contract to be renewed which was indeed granted by the College Council as evidenced by a letter sent by petitioner.
April 22,1998, a letter, whose signatures includes that of the respondents, was sent to Sr. Bernadette. The said letter contain teachers sentiments regarding school policies. However, April 21, 1998, a letter written by the latter was shown, reiterating the conversation of Sr. Bernadette and Remigio regarding the non compliance of respondent to instructional school policies. Accordingly, Sr. Bernadette wrote a letter endorsing the termination of the spouses. Respondents submitted their comments however they were still terminated and their letter for reconsideration denied thus the filling of a complaint for illegal dismissal which was dismissed by both NLRC and LA but was granted by the CA. Petitioners MR was denied hence the present petition.
ISSUE: Whether or not the spouses were illegally dismissed.
HELD:.
LABOR LAW
The Court finds that there was a valid and just cause for dismissal. The Labor Code commands that before an employer may legally dismiss an employee from the service, the requirement of substantial and procedural due process must be complied with. Under the requirement of substantial due process, the grounds for termination of employment must be based on just or authorized causes. Petitioner school charged respondent Remigio Michael of non-compliance with a school policy regarding the submission of final test questions to his program coordinator for checking or comment which was admitted by the respondent in his letter. Respondent Remigio Michael's spouse shared the same defenses and admissions as to the charges against her. The plain admissions of the charges against them were the considerations taken into account by the petitioner school in their decision not to renew the respondent spouses' employment contracts. This is a right of the school that is mandated by law and jurisprudence. It is the prerogative of the school to set high standards of efficiency for its teachers since quality education is a mandate of the Constitution. Schools cannot be required to adopt standards which barely satisfy criteria set for government recognition. The same academic freedom grants the school the autonomy to decide for itself the terms and conditions for hiring its teacher, subject of course to the overarching limitations under the Labor Code.
LABOR LAW
A probationary employee or probationer is one who is on trial for an employer, during which the latter determines whether or not he is qualified for permanent employment. The probationary employment is intended to afford the employer an opportunity to observe the fitness of a probationary employee while at work, and to ascertain whether he will become an efficient and productive employee. The word probationary, as used to describe the period of employment, implies the purpose of the term or period, not its length. It is important that the contract of probationary employment specify the period or term of its effectivity. The failure to stipulate its precise duration could lead to the inference that the contract is binding for the full three-year probationary period. Therefore, the letters sent by petitioner, which were void of any specifics cannot be considered as contracts. The closest they can resemble to are that of informal correspondence among the said individuals. As such, petitioner school has the right not to renew the contracts of the respondents, the old ones having been expired at the end of their terms.
GRANTED
LABOR LAW
A probationary employee or probationer is one who is on trial for an employer, during which the latter determines whether or not he is qualified for permanent employment. The probationary employment is intended to afford the employer an opportunity to observe the fitness of a probationary employee while at work, and to ascertain whether he will become an efficient and productive employee. The word probationary, as used to describe the period of employment, implies the purpose of the term or period, not its length. It is important that the contract of probationary employment specify the period or term of its effectivity. The failure to stipulate its precise duration could lead to the inference that the contract is binding for the full three-year probationary period. Therefore, the letters sent by petitioner, which were void of any specifics cannot be considered as contracts. The closest they can resemble to are that of informal correspondence among the said individuals. As such, petitioner school has the right not to renew the contracts of the respondents, the old ones having been expired at the end of their terms.
GRANTED
