St. Joseph Academy of Valenzuela Faculty Association v. St. Joseph Academy of Valenzuela
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the termination of employment of thirteen (13) non-licensee teachers by St. Joseph Academy of Valenzuela (SJAV). The St. Joseph Academy of Valenzuela Faculty Association (SJAVFA)-FUR Chapter TUCP, representing these teachers, filed a notice of strike against SJAV for alleged illegal termination and union busting. The Secretary of Labor and Employment (SOLE) assumed jurisdiction over the case, which was submitted for voluntary arbitration. 2. Procedural History: The SOLE initially ordered the reinstatement of the thirteen (13) non-licensee teachers with full backwages, contingent on their possession of valid temporary or special permits, and stipulated that their service would be limited to the validity period of these permits. The Court of Appeals (CA), however, deleted the reinstatement and backwages portions of the SOLE's decision. The CA reasoned that reinstatement was no longer feasible as the Department of Education, Culture and Sports assigns para-teachers and SJAV has the right to choose its faculty, with the positions already filled. Furthermore, the CA found no illegal dismissal, thus negating the basis for backwages. 3. The Petition: The petitioner, SJAVFA-FUR Chapter TUCP, filed the present petition for review under Rule 45 of the Rules of Court, seeking to reinstate the SOLE's award of backwages and requesting separation pay in lieu of reinstatement, citing equity and compassionate justice. While acknowledging that reinstatement is impossible due to the expiration of the non-licensees' permits, the petitioner argues for financial assistance based on their years of service and contributions to the school. SJAV, conversely, argues for the dismissal of the petition, asserting that since the non-licensees were not regular employees, reinstatement and backwages are unwarranted.
Issue(s)
Whether the Court of Appeals committed an error in deleting the award of backwages and reinstatement originally granted by the Secretary of Labor and Employment. Whether the non-licensee teachers are entitled to reinstatement and backwages despite not possessing the required licenses under R.A. No. 7836. Whether financial assistance can be awarded to the non-licensee teachers on grounds of equity and social justice, even if reinstatement and backwages are not proper.
Ruling
The petition is PARTIALLY GRANTED. The Court modified the Court of Appeals' decision by ordering respondent St. Joseph Academy of Valenzuela to pay the thirteen (13) non-licensees financial assistance equivalent to one-half (1/2) month's pay for every year of service. The case was remanded to the Department of Labor and Employment for proper computation.
Ratio Decidendi
On the issue of reinstatement and backwages: The Court affirmed the CA's deletion of reinstatement and backwages. It reiterated the principle that these remedies are generally granted only in cases of illegal dismissal. Citing R.A. No. 7836, the Court noted that teaching requires a license, and the non-licensees did not possess the necessary qualifications. Both the SOLE and the CA found no illegal dismissal, a factual finding that binds the Supreme Court in the absence of any circumstance to the contrary. Therefore, since there was no illegal dismissal, the entitlement to reinstatement and backwages, which presuppose such dismissal, was negated. The Court emphasized that the basis for backwages is compensation that should have been earned but was not collected due to unjust dismissal, and this premise was absent in this case. On the issue of entitlement to reinstatement and backwages for non-licensee teachers: The Court upheld the CA's ruling that reinstatement was not possible and backwages were not proper. The Court agreed with the CA that R.A. No. 7836 mandates that only licensed individuals can engage in teaching. The non-licensees, by definition, lacked the required qualification. Consequently, they could not be considered regular employees entitled to the full protection of security of tenure in the context of dismissal. The CA's finding that the dismissal was not illegal, based on the lack of qualification, was deemed correct and binding on the Supreme Court. The Court stressed that the right to reinstatement and backwages is predicated on an unjust dismissal, which was not established here. On the issue of financial assistance on grounds of equity and social justice: The Court, in a departure from the strict application of labor laws, granted financial assistance to the non-licensee teachers. It recognized that while their dismissal was legal due to lack of qualification, it was not due to serious misconduct or any act reflecting on their moral character. The Court considered their years of service (five to nine years) and the fact that SJAV had not shown dissatisfaction with their teaching performance. Citing precedents like Nissan Motor Philippines, Inc. v. Angelo and Pharmacia and Upjohn, Inc. v. Albayda, Jr., the Court invoked equity and social justice to award financial assistance equivalent to one-half (1/2) month's pay for every year of service. This award serves as a measure of compassion for their long service, even though they were not illegally dismissed.
Main Doctrine
While reinstatement and backwages are generally awarded in cases of illegal dismissal, financial assistance may be granted to legally dismissed employees on grounds of equity and social justice, especially when the dismissal is not due to serious misconduct and the employee has rendered substantial service.