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ST. MICHAEL'S INSTITUTE v. CARMELITA A. SANTOS

FACTS:

Petitioner St. Michael's Institute is an institute of learning in Bacoor, Cavite. Respondents Florencio Magcamit, Albert Rosarda, and Carmelita Santos were regular classroom teachers at the school. On August 10, 1993, a public rally was held near the school premises, organized by faculty members, parents, and some students to address issues regarding school facilities and teachers' demands. Petitioner Eugenia Blanco, the school principal, sent memos to the respondents requiring them to explain their involvement in the rally. The respondents denied the accusations and justified their actions as expressions of grievances. An investigation committee was formed by the school, which recommended the termination of the respondents based on their participation in the rally and alleged disrespect towards the school director.

As a result, the respondents were served letters of termination on September 20, 1993. The respondents filed complaints for illegal dismissal, which were initially dismissed by the Labor Arbiter for lack of merit. The Labor Arbiter found that the respondents were guilty of dereliction of duty and insubordination for not conducting classes on August 10, 1993. The NLRC reversed the ruling and held that the termination was illegal, considering the rally's purpose in addressing the grievances of teachers and students. Petitioners brought a petition for certiorari before the Court of Appeals.

The Court referred the petition to the Court of Appeals in accordance with the hierarchy of courts. The Court of Appeals sustained the NLRC's decision but awarded backwages to the respondents. Petitioners filed a petition for review, claiming that the respondents were guilty of serious misconduct warranting their dismissal.

ISSUES:

  1. Whether the respondents were guilty of serious misconduct warranting their dismissal from employment

  2. Whether the dismissal of respondents was due to their deliberate refusal to attend to their classes and utterance of foul and obscene remarks

  3. Whether the respondents' acts of participating in a public rally and missing work for one day constitute serious misconduct and willful disobedience.

  4. Whether the Court of Appeals erred in awarding backwages to the respondents, despite the fact that they did not appeal the NLRC decision.

RULING:

  1. The Court sustained the decision of the NLRC and affirmed the award of backwages to respondents. The appellate court modified the award of backwages to only include until the date respondent Santos would have compulsorily retired. The dismissal of respondents for dereliction of duty and attending a public rally was found to be too harsh a penalty, considering that they were held liable for a first-time offense and were singled out by the petitioners for being officers of the teachers' union they formed. The burden of proof is on the employer to prove that the dismissal was for a just and valid cause, and the penalty imposed must be commensurate with the offense committed. The Court also emphasized that the employer's right to conduct its business and impose penalties must be fair and reasonable.

  2. The Supreme Court held that the respondents' acts did not constitute serious misconduct or willful disobedience. The absence of one day of work to join a public rally does not amount to an offense punishable by dismissal. Therefore, the reinstatement of the respondents is just and proper.

  3. The Court of Appeals did not err in awarding backwages to the respondents. Article 279 of the Labor Code grants an illegally dismissed employee the right to reinstatement or separation pay, if reinstatement is no longer viable, as well as backwages. The award of one relief does not bar the other. The Court of Appeals has the authority and discretion to award backwages even if not specifically appealed by the respondents, if it is necessary for a complete and just resolution of the case or to serve the interests of justice. The award of backwages is a legal consequence of the finding that the respondents were illegally dismissed.

PRINCIPLES:

  • Employer's right to conduct the affairs of the business and impose penalties is a management prerogative, but policies and penalties must be fair and reasonable.

  • Penalties imposed on employees must be commensurate with the offense committed.

  • The burden of proof is on the employer to show that the dismissal was for a just and valid cause.

  • Misconduct as a just cause for termination must be serious and of grave and aggravated character.

  • Disobedience as a just cause for termination must be willful or intentional.

  • Reasonable proportionality must be established between the willful disobedience of an employee and the penalty imposed.

  • An illegally dismissed employee is entitled to the twin reliefs of reinstatement or separation pay, and backwages.

  • Substantive rights like the award of backwages resulting from illegal dismissal must not be prejudiced by a rigid and technical application of rules.

  • Evidence not formally offered before the lower court cannot be considered on appeal.