University of St. La Salle v. Glaraga
REITERATIONFacts
The Antecedents: Respondents, initially engaged as probationary full-time faculty members by petitioner University of St. La Salle, had their teaching loads and schedules reduced to part-time status for the first semester of 2010-2011, citing a decline in enrollment. Their engagements were covered by Documents of Agreement for five-month periods, containing clauses on renewal based on performance, conduct, and academic qualifications (masteral degree for permanency). In the summer and first semester of 2011, respondents were not offered any teaching load or new agreements. Procedural History: Respondents filed a complaint for illegal dismissal, salary differential, damages, and attorney's fees. The Labor Arbiter (LA) found them dismissed for an authorized cause (redundancy) but without procedural due process, ordering separation pay and nominal damages. The National Labor Relations Commission (NLRC) reversed this, stating their probationary employment simply expired and no claims were due. The Court of Appeals (CA) reversed the NLRC, reinstating the LA's decision with modifications, increasing nominal damages to P50,000.00 each due to the university's failure to provide notice to respondents and the Department of Labor and Employment (DOLE). The Petition: Petitioner University of St. La Salle seeks review, arguing the CA erred in finding illegal termination instead of mere expiration of term and in awarding money claims and nominal damages.
Issue(s)
Whether the CA erred in finding that respondents were illegally terminated from employment instead of declaring that their term merely expired. Whether the CA erred in awarding money claims and nominal damages to the respondents.
Ruling
The petition is denied for lack of merit. The assailed Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of whether respondents were illegally terminated or their term merely expired: The Court affirmed the CA's ruling that the respondents were illegally terminated. It reiterated the established jurisprudence that the probationary period for teachers is generally three years, as provided by special regulations, and not the general six-month period under the Labor Code. The Court clarified that fixed-term contracts for teachers, even if for short periods, are reconciled with the three-year probationary period. If the non-renewal of a fixed-term contract occurs within the three-year probationary period, it constitutes a dismissal, not a mere expiration of term, unless the institution expressly adopts a shorter probationary period, which was not evident in this case. The Court found that the petitioner's theory that respondents' rights expired upon termination of their contracts was inconsistent with their initial engagement as full-time probationary teachers. The reduction in load and schedule, while citing decline in enrollment, did not alter their probationary status, and the subsequent non-issuance of agreements within the three-year period amounted to a dismissal. On the issue of whether the CA erred in awarding money claims and nominal damages: The Court found the award of money claims and nominal damages proper. The CA correctly concurred with the LA's finding that the dismissal was due to redundancy, an authorized cause under Article 283 of the Labor Code, given the petitioner's admitted financial difficulties and the evidence presented. However, the Court noted the petitioner's failure to comply with the procedural requirement of prior notice to the employees and the DOLE, as mandated by the Labor Code. Consequently, the CA's award of nominal damages, fixed at P50,000.00 each, was supported by jurisprudence for such procedural lapses, and the petitioner's invocation of honest mistake did not warrant deviation from this established rule.
Main Doctrine
The probationary period for teachers is generally three years, and fixed-term contracts within this period do not automatically terminate employment unless the non-renewal coincides with the expiration of the probationary period. Failure to comply with procedural due process in termination for authorized cause, such as redundancy, warrants nominal damages.