University of the Immaculate Concepcion v. U.I.C. Teaching and Non-Teaching Personnel and Employees Union
REITERATIONFacts
The Antecedents: Petitioner University of the Immaculate Concepcion (UIC) is an educational institution. Petitioners Sister Maria Jacinta de Belen, RVM, Dr. Elvigia Sanchez, Dr. Alicia M. Sayson, and Sister Maria Fulache, RVM, are its officers. Respondent UIC Teaching and Non-Teaching Personnel and Employees Union is the labor representative. Respondent Elman Gubaton was terminated for accepting money for grades, brokering grades, and borrowing money from students. Respondents George Vergara and Victoria Raneses, along with 14 probationary teachers, were terminated, with UIC citing redundancy for Vergara and unsatisfactory performance for the probationary teachers. Procedural History: Gubaton and the union filed a suit for unfair labor practice, illegal suspension, damages, and attorney's fees. The 16 other employees filed a similar complaint. The cases were consolidated. The Labor Arbiter declared Gubaton's termination legal but awarded him P10,000.00 for denial of procedural due process. She ordered the reinstatement of Vergara, Raneses, and the 14 teachers with backwages, finding UIC guilty of unfair labor practice and awarding moral and exemplary damages. The NLRC affirmed Gubaton's termination as valid but reduced the indemnity to P5,000.00. It set aside the finding of unfair labor practice, affirmed the illegal termination of Vergara and Raneses with reinstatement and backwages, and ruled that the 14 teachers' contracts merely expired, thus not entitled to reinstatement or backwages, but ordered payment of unpaid 13th-month pay. The NLRC also ordered backwages for the 14 teachers from the date of the Labor Arbiter's decision to the promulgation of the NLRC resolution. The Court of Appeals affirmed the NLRC decision with modifications, deleting the award of backwages and attorney's fees for the 14 teachers. The Petition: Petitioners appealed to the Supreme Court, contending that the Labor Arbiter's decision was a nullity due to partiality and bias, that Vergara and Raneses were validly dismissed, and that the award to Gubaton for denial of procedural due process was erroneous.
Issue(s)
Whether the Labor Arbiter's decision was a patent nullity due to alleged partiality and bias. Whether George Vergara was validly dismissed on the ground of redundancy. Whether Victoria Raneses was validly dismissed due to unsatisfactory performance. Whether Elman Gubaton was denied procedural due process.
Ruling
The Supreme Court affirmed the Court of Appeals' decision with a modification: the award of P5,000.00 to Elman Gubaton was deleted. The Court found that Gubaton was afforded procedural due process and thus not entitled to indemnity for its alleged denial.
Ratio Decidendi
On the alleged partiality and bias of the Labor Arbiter: The Court found no merit in the petitioners' contention. The Labor Arbiter acted within her discretion in admitting the respondents' belated position paper, as she is mandated to ascertain facts speedily and objectively without technicalities. The failure to submit a position paper on time is not a ground for striking it out or dismissing a complaint. Petitioners' withdrawal of their motion for leave to file a reply, despite it being granted, was their own doing. The Court also stated that error in judgment is not equivalent to undue bias or grave abuse of discretion. The NLRC, after considering all evidence, set aside the Labor Arbiter's decision, indicating that the proceedings were not fundamentally flawed. On the dismissal of George Vergara: The Court found the contention without merit. Redundancy exists when an employee's services are in excess of what is reasonably demanded by the enterprise's actual requirements. Petitioners did not claim the electrician position was abolished or superfluous. The fact that a student-trainee performed the same tasks indicated a need for the position. The Court of Appeals correctly noted that there was no abolition of a position to reduce personnel; rather, the student-trainee simply replaced Vergara, who was performing the same functions for free, which was advantageous to the employer. This constituted a replacement, not a valid redundancy dismissal. On the dismissal of Victoria Raneses: The Court found the contention without merit. Petitioners' claim that Raneses was hired on a probationary basis on November 1, 1993, was contradicted by their own position paper stating she was hired in 1985 and paid by both the university and the alumni association. The assertion that no employer-employee relationship existed due to lack of control over her work or schedule was not given credence due to the absence of corroborative proof and the prior findings. The Court upheld the findings that Vergara and Raneses were illegally dismissed and thus entitled to reinstatement and full backwages. On the denial of procedural due process to Elman Gubaton: The Court reversed the findings of the Labor Arbiter and the NLRC. Gubaton was informed of the charges, denied them, and demanded a formal investigation with representation. He was notified of the investigation date. However, he filed a motion for postponement which was denied. Despite being represented by union officers, Gubaton and the officers walked out. The investigating committee proceeded with the hearing, presenting eight witnesses whose testimonies supported the charges. Gubaton was found guilty based on this uncontroverted evidence. The Court held that due process is satisfied by a reasonable opportunity to explain one's side, which Gubaton was afforded but chose not to avail of after his motion for postponement was denied. Therefore, the award of indemnity for denial of procedural due process was deleted.
Main Doctrine
The Court modified the Court of Appeals' decision by deleting the award of indemnity to Elman Gubaton, finding that he was afforded procedural due process despite his absence from the investigation, as he was given notice and an opportunity to be heard but chose not to participate after his motion for postponement was denied.