GR 137795; (March, 2003) (Digest)
G.R. No. 137795 ; March 26, 2003
COLEGIO DE SAN JUAN DE LETRAN CALAMBA, petitioner, vs. BELEN P. VILLAS, respondent.
FACTS
Respondent Belen P. Villas, a high school teacher, was granted a one-year study leave without pay from June 1995 to March 1996, subject to conditions in the Faculty Manual. One condition stated that engaging in outside employment during the leave would be regarded as resignation. During the first semester, Villas did not enroll in her intended master’s program but instead took a religious course and engaged in part-time selling. She later enrolled in and passed education units at another college in the second semester. The school, upon her return, deemed her actions a violation of the leave conditions, constituting deception and grounds for resignation. After grievance proceedings led to a deadlock, the case was elevated to voluntary arbitration.
The Voluntary Arbitrator ruled that Villas was illegally dismissed, ordering her reinstatement with full backwages. The Court of Appeals affirmed this decision. The school elevated the case to the Supreme Court, arguing the dismissal was lawful due to Villas’s violation of contractual and manual provisions, which constituted serious misconduct.
ISSUE
Whether respondent Villas was illegally dismissed.
RULING
Yes, the dismissal was illegal. For a valid dismissal, both substantive and procedural due process must be satisfied. Procedurally, the employer must provide two written notices: one specifying the grounds for dismissal and another communicating the decision. The school failed in this regard, as its June 3, 1996 letter to Villas was a final termination notice without a prior notice to explain. Substantively, the alleged violations did not constitute serious misconduct warranting dismissal. Villas’s failure to enroll in the first semester and her part-time selling did not amount to the willful disobedience or breach of trust required under Article 282 of the Labor Code. The study leave conditions were ambiguous and subject to strict interpretation against the drafter (the school). Her subsequent enrollment in the second semester showed her intent to study, and her part-time activity, while technically a violation, was not so grave as to justify termination. Thus, the absence of both valid cause and procedural due process rendered the dismissal illegal. The Supreme Court denied the petition and affirmed the reinstatement order with full backwages.