St. Paul College, Pasig v. Mancol
REITERATIONFacts
The Antecedents: Respondents Anna Liza L. Mancol and Jennifer Cecile Valera were employed as pre-school teachers by petitioner St. Paul College, Pasig (SPCP). Mancol filed a leave of absence for a fertility check-up abroad, and upon her return, was required to explain why she should not be dismissed for taking an unapproved leave. She alleged being barred from teaching, entering her classroom, and performing other duties. Valera took a leave of absence for scoliosis surgery. Upon her return, she was advised to file a leave for the entire school year or be reassigned, and was required to submit a waiver and a physician's certification of fitness to work. She alleged constructive dismissal due to being stripped of her teaching load and forced to take a leave. Procedural History: Respondents filed a complaint for constructive dismissal, non-payment of overtime pay, holiday pay, and other monetary claims. The Labor Arbiter ruled in favor of the respondents, finding them constructively dismissed and ordering reinstatement and payment of monetary awards. The National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, dismissing the complaint. The Court of Appeals (CA) granted the respondents' petition for certiorari, reversing the NLRC decision and reinstating the Labor Arbiter's decision with modifications, including the deletion of overtime and holiday pay awards but adding moral and exemplary damages. The CA later clarified that in lieu of reinstatement, respondents were entitled to separation pay. The Petition: Petitioners seek to reverse the CA's decision, arguing that there was no constructive dismissal, that the respondents abandoned their posts, and that the CA erred in awarding backwages, separation pay, and other monetary benefits. They also dispute the CA's finding of preventive suspension for Mancol and the solidary liability of Sister Teresita Baricaua.
Issue(s)
Whether respondents Anna Liza L. Mancol and Jennifer Cecile Valera were constructively dismissed. Whether the respondents abandoned their work. Whether the Court of Appeals erred in awarding backwages, separation pay, moral and exemplary damages, and attorney's fees. Whether Sister Teresita Baricaua can be held solidarily liable with St. Paul College, Pasig.
Ruling
The petition is denied for lack of merit. The Decision dated April 16, 2015, and the Resolution dated January 8, 2016, of the Court of Appeals in CA-G.R. SP No. 124501 are affirmed.
Ratio Decidendi
On the issue of constructive dismissal: The Court affirmed the CA's finding that Mancol and Valera were constructively dismissed. Constructive dismissal arises when continued employment is rendered impossible, unreasonable, or unlikely; when there is a demotion in rank and/or diminution in pay; or when clear discrimination, insensibility, or disdain by an employer becomes unbearable. The Court found that the petitioners' actions, such as barring Mancol from her duties upon return from leave and forcing Valera to take a year-long leave or be reassigned, rendered their continued employment impossible and unreasonable. The test is whether a reasonable person in the employee's position would have felt compelled to give up their position under the circumstances, and the petitioners' acts were gratuitous, unjustified, and unwarranted. On the issue of abandonment of work: The Court held that the petitioners failed to prove abandonment of work by either Mancol or Valera. For abandonment to be validly established, the employer must prove the concurrence of the employee's failure to report for work for no valid reason and a categorical intention to discontinue employment. The records showed that both respondents attempted to return to work but were prevented by the petitioners, indicating no intention to abandon their positions. Their immediate filing of a complaint for constructive dismissal further belied any claim of abandonment. On the award of monetary benefits: The Court upheld the CA's modified award, which deleted overtime and holiday pay but affirmed backwages (reckoned from the date of dismissal until reinstatement or finality of decision), moral and exemplary damages, and attorney's fees. The CA's clarification that separation pay in lieu of reinstatement was awarded was also sustained. The Court reiterated that backwages are a consequence of illegal dismissal, and damages are awarded when an employee suffers mental anguish due to the employer's bad faith or oppressive conduct. On the solidary liability of Sister Teresita Baricaua: The Court affirmed the solidary liability of Sister Baricaua. While she acted in her official capacity, the Court has consistently held that corporate officers may be held solidarily liable with the corporation for illegal dismissal cases if they acted with malice or bad faith, or if their actions directly caused the dismissal. The harsh remarks and actions attributed to Sister Baricaua in forcing the respondents to resign or take extended leaves demonstrated bad faith and malice, justifying her solidary liability.
Main Doctrine
The Court affirmed the Court of Appeals' finding that the respondents were constructively dismissed, holding that the petitioners' actions rendered continued employment impossible, unreasonable, or unlikely, constituting a dismissal in disguise. The Court also reiterated the principles governing constructive dismissal, abandonment of work, and the respective jurisdictions of labor tribunals.