G.R. No. 119512 July 13, 1998
St. Michael Academy and Sister Patricia Aguilar, petitioners, vs. The National Labor Relations Commission, Hermie Bolosiño, Ederlinda Rebadulla, Ferliza Golo, Imelda Aleria, Bernardita Oserraos, Ceferina Daclag and Josephine Delorino, respondents.

FACTS

Petitioner St. Michael Academy is an educational institution in Catarman, Northern Samar, with petitioner Sister Patricia Aguilar as its principal. Private respondents are former teachers of the school. The case originated from a complaint for terminal pay filed by Bolosiño and Delorino on July 9, 1992. They later filed a new complaint for separation pay. In their position paper, petitioners presented the resignation letters of Bolosiño and Delorino to prove voluntary resignation. In September 1992, Bolosiño and Delorino filed an unverified position paper joined by seven other former teachers (Gallano, Daclag, Aleria, Oserraos, Rebadulla, Tan, and Golo), who alleged new claims for wage differentials, vacation and sick leave benefits, separation pay, and other benefits. These seven teachers claimed they were forced to resign after rallying against the school for not releasing their share in a tuition fee increase. Petitioners objected to the inclusion of new parties and claims. Five of these teachers (Oserraos, Daclag, Aleria, Golo, and Rebadulla) later filed individual complaints in November 1992. The Labor Arbiter decided in favor of the complainants, awarding various monetary claims including salary differentials, 13th month pay, separation pay, and damages. The NLRC affirmed with modification, deleting the award of damages and service incentive leave pay and denying some claims due to prescription, resulting in a total award of P320,275.42. Petitioners assailed the NLRC decision before the Supreme Court.

ISSUE

1. Whether private respondents are entitled to payment of salary differentials, 13th month pay, vacation leave pay, and service incentive leave pay.
2. Whether private respondents Bolosiño, Daclag, and Oserraos were illegally dismissed by being forced to resign.
3. Whether private respondents’ failure to follow the rules of procedure in labor cases violated petitioners’ right to due process.

RULING

The Supreme Court affirmed the NLRC decision with modification.
1. On the monetary awards: The Court held that the general prayer for “all other benefits” in the complainants’ position paper was sufficient to justify the award of 13th month pay and vacation leave pay, as technical rules are not binding in labor proceedings. However, the claim for service incentive leave pay was correctly deleted by the NLRC as it was not specifically prayed for. The Court recalculated the salary differentials based on the applicable minimum wage laws and found that some complainants were indeed underpaid. The defense of prescription was rejected for being raised only in the petitioners’ reply, not in their position paper.
2. On illegal dismissal: The Court found that the resignations of Bolosiño, Daclag, and Oserraos were involuntary. They were forced to resign after participating in a rally, constituting constructive dismissal. They are entitled to separation pay and backwages. The resignations of Delorino, Rebadulla, Golo, and Aleria were deemed voluntary, so they are not entitled to separation pay.
3. On procedural due process: The Court held that no due process was violated. Petitioners were given ample opportunity to present their case, file pleadings, and submit evidence. The Labor Arbiter’s actions were in line with the liberal application of procedural rules in labor cases to achieve substantial justice.
The monetary awards were recomputed, resulting in a total award of P320,275.42 as modified by the NLRC.