G.R. No. 234186, November 21, 2018
Union School International represented by Pastor Abraham Cho, Jaime Nabua, and Jennifer Mandapat, Petitioners, v. Charley Jane Dagdag, Respondent.

FACTS

Respondent Charley Jane Dagdag was a probationary elementary school teacher at Union School International. In November 2012, she informed the school head, Jennifer Mandapat, that she was eight weeks pregnant and that the father of the child was marrying another woman. The school subsequently initiated disciplinary proceedings against Dagdag for “gross immorality” based on her pregnancy out of wedlock. During a grievance committee hearing, Dagdag was presented with two options: to resign or to be dismissed. She initially agreed to resign but later filed a complaint for illegal dismissal, claiming she was coerced.
The Labor Arbiter ruled in Dagdag’s favor, finding constructive illegal dismissal and ordering the payment of backwages and damages. The National Labor Relations Commission (NLRC) reversed this decision, dismissing the complaint for lack of merit. It found no substantial evidence of constructive dismissal, noting Dagdag’s initial agreement to resign. On appeal via certiorari, the Court of Appeals annulled the NLRC ruling, reinstating the Labor Arbiter’s decision and declaring Dagdag’s dismissal illegal for being based solely on her pregnancy.

ISSUE

Whether the respondent was illegally dismissed from her employment.

RULING

Yes, the Supreme Court affirmed the Court of Appeals’ decision, ruling that Dagdag was illegally dismissed. The Court held that her termination, premised on her pregnancy out of wedlock, constituted discrimination solely on account of her sex, which is expressly prohibited under Article 135 of the Labor Code. The petitioners failed to prove that Dagdag’s pregnancy amounted to “gross immorality” justifying dismissal under Article 282 of the same Code.
The legal logic is anchored on the principle that for an act to be considered immoral as a just cause for termination, it must contravene not just a private institution’s sectarian moral views but also established public and secular standards of conduct. Citing precedents like Leus v. St. Scholastica’s College and Capin-Cadiz v. Brent Hospital, the Court emphasized that pregnancy out of wedlock, by itself, is not inherently disgraceful or immoral under prevailing societal norms absent a legal impediment to marry between the parties at the time of conception. The petitioners presented no substantial evidence that Dagdag’s specific conduct was considered disgraceful within the community’s secular standards. The totality of circumstances, including the school’s presentation of a coercive choice between resignation and dismissal upon learning of the pregnancy, established that the dismissal was grounded on discrimination rather than a valid, substantive cause supported by law and evidence.