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WOODRIDGE SCHOOL v. JOANNE C. PE BENITO

FACTS:

This case involves the dismissal of Joanne C. Pe Benito and Randy T. Balaguer, probationary teachers at Woodridge School. The teachers raised various issues in a manifesto presented to the school, including the alleged NEAT/NSAT anomaly and the right to due process. When the issues were not resolved, they filed a formal complaint with the Department of Education, Culture and Sports (DECS). As a result, they were placed under preventive suspension and eventually terminated by the school, citing grounds such as defamatory remarks, spreading false accusations, and failure to meet performance standards. The teachers filed a complaint for illegal suspension and later amended it to include illegal dismissal. The Labor Arbiter upheld the termination, but the Court of Appeals (CA) set aside the decision, ruling that the suspension was illegal and that the teachers' acts were indications of their concern for integrity. The CA also rejected the school's argument that the teachers did not qualify for permanent employment. The case was appealed to the Supreme Court, with the petitioner questioning the CA's decision.

ISSUES:

  1. Whether the Court of Appeals (CA) erred in setting aside the procedural infirmity and allowing the petition to proceed despite the failure to comply with the mandatory requirements on the certificate of non-forum shopping.

  2. Whether the dismissal and preventive suspension of the respondents were valid.

  3. Whether or not the respondents' actions constitute serious misconduct warranting dismissal from employment.

  4. Whether or not the petitioner complied with the procedural aspect of lawful dismissal.

  5. Whether the preventive suspension of the respondents was valid.

  6. Whether the respondents are entitled to reinstatement and full backwages.

  7. Whether the award of moral and exemplary damages to the respondents is proper.

RULING:

  1. The CA did not commit an error in setting aside the procedural infirmity and allowing the petition to proceed. Strict compliance with the provisions regarding the certificate of non-forum shopping is mandatory, but substantial compliance is permitted under justifiable circumstances.

  2. The dismissal of the respondents was invalid. As probationary employees, they still enjoyed security of tenure during their probationary employment. Their contracts of employment were terminated before they could qualify as regular employees, but the notices of termination failed to explain in detail the "failure to qualify" and the specific standards not met by the respondents. Furthermore, petitioner failed to substantiate their allegations with documentary evidence, such as evaluation reports, which ultimately rendered their dismissal invalid.

  3. The Court held that the respondents' actions did not constitute serious misconduct warranting dismissal. The misconduct must be of a grave and aggravated character and must be in connection with the work of the employee to constitute just cause for separation. In this case, the actions of the respondents were in good faith and aimed at addressing legitimate grievances. There was no finding of malice or wrongful intent attributable to the respondents.

  4. The Court found that the petitioner had complied with the procedural aspect of lawful dismissal. The respondents were given written notice specifying the grounds for termination and were afforded the opportunity to explain their side. They were also given a hearing and the chance to present evidence. However, the dismissal was still held to be illegal due to the petitioner's failure to satisfy the substantive aspect of due process.

  5. The preventive suspension of the respondents was held to be illegal. The employer can only place a worker under preventive suspension if the continued employment of the worker poses a serious and imminent threat to the life or property of the employer or co-workers. In this case, the grounds cited for the preventive suspension did not pose a threat to the life or property of the school, teachers, or students.

  6. As probationary employees, the respondents' security of tenure is limited to the period of their probation. Since they were not extended new appointments, they are not entitled to reinstatement and full backwages. They are only entitled to their salary for the 30-day preventive suspension and, in the case of one respondent, backwages for the unexpired term of their probationary employment.

  7. The award of moral and exemplary damages to the respondents was upheld. The dismissal of an employee can justify the award of moral damages if it is attended by bad faith, fraud, or if it constitutes an act oppressive to labor. Exemplary damages may be awarded if the dismissal is done in a wanton, oppressive, or malevolent manner. In this case, the bad faith on the part of the employer in exerting pressure to silence the employees regarding their grievances was established, resulting in loss, prejudice, and damage to the employees.

PRINCIPLES:

  • The requirement of strict compliance with the provisions regarding the certificate of non-forum shopping does not preclude substantial compliance under justifiable circumstances.

  • Technicalities take a backseat vis-à-vis substantive rights.

  • Probationary employees cannot claim security of tenure and compel their employers to renew their employment contracts upon expiration, but their dismissal must still be for a valid cause.

  • Before an employer may legally dismiss an employee, substantial and procedural due process must be complied with.

  • Misconduct must be serious, willful, and imply wrongful intent to be considered as a valid cause for termination of employment.

  • Serious misconduct, to constitute just cause for separation, must be of a grave and aggravated character and must be in connection with the work of the employee.

  • The act or conduct complained of must be performed with wrongful intent.

  • The procedural aspect of lawful dismissal requires giving the employee a written notice specifying the grounds for termination, conducting a hearing or conference where the employee can respond to the charges and present evidence, and giving a written notice of termination indicating the grounds have been established.

  • The substantive aspect of due process requires the employer to establish just cause for termination.

  • The employer can place a worker under preventive suspension if the continued employment of the worker poses a serious and imminent threat to the life or property of the employer or co-workers.

  • As probationary employees, the security of tenure of the employees is limited to the period of their probation.

  • Moral and exemplary damages may be awarded to an employee if the dismissal is attended by bad faith, fraud, or if it constitutes an act oppressive to labor. Additional facts must be pleaded and proven to show that the act of dismissal was attended by bad faith, fraud, etc., and that social humiliation, wounded feelings, and grave anxiety resulted therefrom.