GR 117514; (October, 1996) (Digest)
G.R. No. 117514 October 4, 1996
MT. CARMEL COLLEGE, BISHOP JULIO LABAYEN and SR. MERCEDES SALUD, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and MRS. NORMITA A. BAÑEZ, respondents.
FACTS
Petitioner Mt. Carmel College hired respondent Normita A. Bañez as a grade school teacher under a Contract of Probationary Employment dated June 1, 1989. Paragraph 5 of the contract stipulated that her employment “shall be deemed to run from SY 1989-1990 to SY 1991-1992 (day to day of month to month)” and that her service could be terminated at any time if she failed to comply with the school’s conditions. In March 1992, the school terminated Bañez’s services for her failure to pass the National Teacher’s Board examination.
Bañez filed a complaint for illegal dismissal. The Labor Arbiter ruled in her favor, but the National Labor Relations Commission (NLRC) reversed the finding of illegal dismissal. However, the NLRC ordered the petitioners to pay Bañez P10,200.00, representing her salary for the alleged unexpired portion of her probationary period from March to June 1992. The petitioners assail this monetary award.
ISSUE
Whether the NLRC gravely abused its discretion in finding an “unexpired portion” of Bañez’s probationary contract ending in June 1992 and holding petitioners liable for salary corresponding to that period.
RULING
The Supreme Court granted the petition and set aside the NLRC’s monetary award. The legal logic hinges on the correct interpretation of the contract’s duration clause and the distinction between a school year and a calendar year. The contract explicitly stated that employment was for school years (SY) 1989-1990 to 1991-1992. Citing Section 48 of the Manual of Regulations for Private Schools and jurisprudence (Espiritu Santo Parochial School vs. NLRC; Colegio San Agustin vs. NLRC), the Court emphasized that a school year, not a calendar year, governs academic employment. A school year typically begins in June of one calendar year and ends in March of the next, spanning approximately ten months.
Therefore, the probationary period from SY 1989-1990 to SY 1991-1992 commenced in June 1989 and concluded legally at the closing of SY 1991-1992 in March 1992. The NLRC erroneously assumed the contract would expire in June 1992, treating it as a calendar year endpoint. Since Bañez’s termination in March 1992 coincided with the natural expiration of her fixed-term contract as defined by the school years specified, there was no unexpired portion for which she was entitled to payment. The petitioners’ obligation ceased upon the contract’s lawful termination in March.