St. Mary's College (Tagum, Davao) v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioners, St. Mary's College and its directress, principal, and cashier, were accused by private respondents, faculty members, of unfair labor practice. The private respondents circulated a "Manifesto" accusing the petitioners of forcing teachers to sign affidavits waiving benefits, blacklisting teachers, terminating teachers without proper evaluation, and suppressing union organization by creating fear. The Manifesto demanded the replacement of the petitioners. Procedural History: Upon investigation, the private respondents admitted authorship of the Manifesto. The school terminated the services of three faculty members for gross insubordination and serious disrespect and did not renew the probationary contracts of three others. The private respondents, with their union, filed a complaint for illegal dismissal and unfair labor practice. The Labor Arbiter found the petitioners guilty of unfair labor practice and ordered reinstatement with backwages. The National Labor Relations Commission (NLRC) affirmed this decision, except for the award of damages. Petitioners' motion for reconsideration was denied. The Petition: Petitioners filed a petition for certiorari, claiming they were deprived of due process for not being allowed to cross-examine private respondents and rebut their evidence.
Issue(s)
Whether the petitioners were denied due process by the labor arbiter and the National Labor Relations Commission (NLRC). Whether the private respondents were guilty of Unfair Labor Practice (ULP) and if the dismissal of the faculty members was valid.
Ruling
The questioned decisions of the NLRC are reversed, and the complaint against the petitioners is dismissed.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the requirements of due process were satisfied. In administrative proceedings, the standard of due process is the 'opportunity to be heard.' The Court held that since the parties were heard at the inception of the case and later agreed to submit their respective position papers for resolution when settlement failed, the procedural requirements were met. Citing Gonzales v. Hon. Sec. of Labor (116 SCRA 575), the Court emphasized that a decision based on position papers which are sufficient to apprise the adjudicator of the facts meets the requirements of a fair and open hearing. Consequently, the lack of a trial-type hearing with cross-examination did not constitute a violation of due process in this labor dispute. On Issue 2: The Court found that there was no substantial evidence to support the finding of Unfair Labor Practice (ULP). For evidence to be substantial, it must first be credible, and the record showed that the vast majority of the faculty members (68 out of over 80) explicitly denied that the administration interfered with their right to self-organization. Furthermore, 77 teachers denied the existence of a 'blacklist' as alleged by the respondents. The Court noted that the private respondents lacked the support of a substantial number of their colleagues, making the claim of an ongoing union-organizing effort hard to believe, especially since they could not even meet the thirty percent (30%) subscription requirement for a certification election. On the contrary, the private respondents' admitted authorship of the Manifesto, which ridiculed the petitioners and disrupted school decorum, constituted 'gross misconduct.' Therefore, the Court concluded that the dismissal was for a just cause and not an act of ULP, leading to the reversal of the NLRC decision.
Main Doctrine
The dismissal of employees for circulating a manifesto criticizing school administration, which manifesto is not supported by a substantial number of faculty members and constitutes gross misconduct, is a just cause for termination and does not constitute unfair labor practice. The requirements of due process are satisfied when parties are given the opportunity to submit position papers.