GR 127241; (September, 2001) (Digest)
G.R. No. 127241 September 28, 2001
LA CONSOLACION COLLEGE, SR. ROSALINDA BAYLA, SR. CELIA BAYONA, REODITA MABAYAG, JUDITH VERDADERO and JOSE BAYOGUING, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and JOSE DE LA PEÑA, III, respondents.
FACTS
Jose de la Peña III was initially employed by La Consolacion College (LCC) from 1975 until his resignation in 1980. In 1992, after more than a decade, he was re-hired by LCC under a written contract expressly stipulating that his employment as a classroom teacher in Physical Education and Health was for a fixed term of one academic year, from June 1992 to March 1993. During this period, de la Peña repeatedly failed to comply with school requirements such as the submission of lesson plans and class records, and he engaged in serious misconduct by berating and threatening a school official during a faculty meeting. Upon the contract’s expiration, LCC informed him he would not be re-hired due to unsatisfactory performance. De la Peña filed a complaint for illegal dismissal.
ISSUE
Whether the National Labor Relations Commission committed grave abuse of discretion in ruling that Jose de la Peña III was a regular employee who was illegally dismissed.
RULING
The Supreme Court reversed the NLRC decision. The Court held that the NLRC committed grave abuse of discretion. The applicable law for determining the employment status of private school teachers is the Manual of Regulations for Private Schools, not the general provisions of the Labor Code. Under the Manual, a teacher acquires permanent status only upon rendering three consecutive years of satisfactory service. De la Peña’s employment was governed by a clear written contract for a fixed term of one school year. He was a new hire in a position he had never held before, and he did not complete the requisite three-year probationary period. His failure to comply with school directives and his misconduct further demonstrated that his service was not satisfactory. Consequently, his fixed-term contract simply expired, and non-renewal did not constitute illegal dismissal. He did not attain regular status and was not entitled to security of tenure.