St. Theresa's School of Novaliches Foundation v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondent Esther Reyes was hired by petitioner St. Theresa's School of Novaliches Foundation, represented by petitioner Adoracion Roxas, on a contract basis from June 1, 1991, to March 31, 1992. Private respondent commenced work on May 2, 1991. During her employment, she took approved leaves of absence from February 17 to 21 and February 24 to 28, 1992. Upon returning on March 2, 1992, she stayed only from 6:48 to 9:38 a.m. and did not return thereafter. Petitioners theorized abandonment, while private respondent claimed she was replaced by Annie Roxas, daughter of petitioner Adoracion Roxas, and her belongings were moved. On March 25, 1992, petitioners sent a letter informing her that her contract would not be renewed. Prior to this, on March 3, 1992, private respondent filed a complaint for unfair labor practice, illegal dismissal, and other monetary claims. Procedural History: The Labor Arbiter declared the dismissal illegal and ordered reinstatement with full backwages, moral and exemplary damages, and attorney's fees. Petitioners appealed to the NLRC. Private respondent filed a Motion for Partial Execution. The NLRC, in a Resolution dated November 29, 1994, reversed the Labor Arbiter's decision, declaring the separation of Esther Reyes legal and valid, but directed payment of backwages from November 12, 1993, to the date of the Resolution. Both parties moved for reconsideration. The NLRC, in a Decision dated November 29, 1995, denied the motions for reconsideration. Private respondent filed a Motion for Execution, but no writ was issued. Petitioners filed the present petition questioning the award of backwages. The Petition: Petitioners contend that the NLRC acted with grave abuse of discretion in awarding backwages despite finding the dismissal valid.
Issue(s)
Whether the NLRC gravely abused its discretion in awarding backwages despite finding the dismissal of the private respondent to be legal and valid. Whether the fixed-term employment contract was valid.
Ruling
The petition is GRANTED. The Decision of the respondent NLRC rendered on November 29, 1995, is MODIFIED by deleting the award of backwages.
Ratio Decidendi
On the issue of backwages: The term "backwages" refers to earnings lost due to illegal dismissal and is granted on grounds of equity to restore income lost by reason of unlawful dismissal. It is awarded to further public objectives of the Labor Code and is a form of public reparation for an unlawful act or bad faith by the employer. However, jurisprudence consistently awards backwages to illegally dismissed employees. In cases where the dismissal has been adjudged valid and lawful, as in this case, the challenged award of backwages is decidedly improper and contrary to law and jurisprudence. The private respondent's employment was validly terminated, and therefore, she is not entitled to backwages. On the validity of the fixed-term employment contract: Article 280 of the Labor Code does not prohibit fixed-term employment contracts, provided they are entered into freely and without vitiated consent. The contract between the parties, providing a fixed term of nine months, was not contrary to law, morals, good customs, public order, or public policy, and therefore, it was valid and binding. Private school teachers require specific conditions for permanent employment, including full-time status, at least three consecutive years of satisfactory service, which were not met by the private respondent in this case.
Main Doctrine
The award of backwages is improper when the dismissal of an employee has been adjudged valid and lawful.