Mt. Carmel College v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioner Mt. Carmel College hired private respondent Normita A. Bañez as a grade school teacher under a written Contract of Probationary Employment. The contract stipulated her salary and duration, stating her employment "shall be deemed to run from SY 1989-1990 to SY 1991-1992 (day to day of month to month)" and could be terminated if she failed to comply with conditions. Procedural History: In March 1992, the school terminated private respondent's services for failing to pass the National Teacher's Board examination. Private respondent filed a complaint for illegal dismissal. The Labor Arbiter found the dismissal illegal and ordered reinstatement with backwages. Petitioners appealed to the National Labor Relations Commission (NLRC). The Petition: The NLRC reversed the Labor Arbiter, finding the dismissal legal. However, the NLRC ordered petitioners to pay private respondent P10,200.00, representing her salary for the unexpired portion of her probationary period, which it determined ended in June 1992, three months after her termination in March 1992. Petitioners assailed the NLRC's decision, arguing grave abuse of discretion in finding an "unexpired portion" in a contract that expires at the end of the school year 1991-1992.
Issue(s)
Whether the NLRC gravely abused its discretion in finding an "unexpired portion" in private respondent's probationary contract. Whether petitioners are liable for the payment of private respondent's salary equivalent to that "unexpired portion".
Ruling
The petition is impressed with merit. The award of P10,200.00 in favor of private respondent is SET ASIDE.
Ratio Decidendi
On whether the NLRC gravely abused its discretion in finding an "unexpired portion" in private respondent's probationary contract: The Court found that the NLRC gravely abused its discretion. The employment contract clearly stipulated that private respondent's employment "shall be deemed to run from SY 1989-1990 to SY 1991-1992 (day to day of month to month)". This duration is defined by the school year, not the calendar year. Under Section 48 of the Manual of Regulations for Private Schools, a school year consists of approximately forty weeks, typically running from June of one calendar year to March of the succeeding calendar year. The Court has previously distinguished between a calendar year and a school year in cases such as Espiritu Santo Parochial School vs. NLRC and Colegio San Agustin vs. NLRC. In those cases, it was clarified that a school year is not equivalent to a full calendar year, as it comprises only about ten months. Therefore, the NLRC erred in concluding that private respondent's probationary employment was supposed to end in June 1992. On whether petitioners are liable for the payment of her salary equivalent to that "unexpired portion": The contract explicitly stated the term ended at the closing of school year 1991-1992, which is in March 1992. Consequently, petitioners are not obligated to pay private respondent her salary for April, May, and June, as her employment had already ceased in March in accordance with the terms of her contract. The finding of an "unexpired portion" was thus erroneous, rendering the award of P10,200.00 unjustified.
Main Doctrine
A probationary employment contract for a school teacher, stipulating duration by school year, ends at the closing of the last school year, not at the end of the calendar year. The school is not liable for salary for the period after the school year's closing.