GR 100629; (July, 1996) (Digest)
G.R. No. 100629 July 5, 1996
ENELYN E. PEÑA, ERLINDA A. BIRON, FLORDELIZA A. ABOGADO, ROSARIO A. RAÑA, MA. LUISA P. LANUZA and JOSEPHINE S. DELA CRUZ, petitioners, vs. THE NATIONAL LABOR RELATIONS COMMISSION, NAGA PAROCHIAL SCHOOL, MSGR. JAIME M. SAN ANDRES and FLAVEL C. FAVOREAL, respondents.
FACTS
Petitioners were permanent teachers at Naga Parochial School, having served for over three years. On May 4, 1988, they received notices of termination for failing to meet the school’s requirement of a minimum 85% efficiency rating for the two preceding school years (1985-1986 and 1986-1987). They filed a complaint for illegal dismissal. The Labor Arbiter ruled in their favor, finding the rating criteria unclear and arbitrary, and ordered their reinstatement with backwages.
On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision. The NLRC found that petitioners had been sufficiently warned after their initial low ratings and were given time to improve, but still failed to meet the standard. However, considering their length of service, the NLRC awarded them separation pay equivalent to one month’s salary per year of service.
ISSUE
Whether the NLRC committed grave abuse of discretion in upholding the validity of petitioners’ dismissal based on their failure to meet the school’s 85% minimum efficiency rating.
RULING
The Supreme Court dismissed the petition, finding no grave abuse of discretion by the NLRC and upholding the legality of the dismissal. The Court emphasized the management prerogative of educational institutions to set reasonable academic standards for their teachers in pursuit of quality education, a constitutional mandate. Petitioners’ argument that an 85% rating was unreasonable, as the general average is 75%, was rejected. The school’s evaluation system was detailed, involving multiple evaluators and considering various factors beyond classroom teaching. Petitioners did not timely object to the criteria or their specific numerical ratings when they were informed after each evaluation period.
The Court noted that only six out of forty-seven teachers failed to meet the rating, proving the standard was attainable and not imposed in bad faith. While petitioners, as permanent employees, enjoyed security of tenure, this guarantee cannot shield incompetence or deprive an employer of its right to demand reasonable performance standards. The dismissal was for a just cause—failure to meet a reasonable performance standard despite sufficient warning and opportunity to improve. The grant of separation pay by the NLRC adequately balanced the employer’s prerogative with recognition of petitioners’ past service.