G.R. No. 160240 October 29, 2008
WOODRIDGE SCHOOL (now known as WOODRIDGE COLLEGE, INC.), Petitioner, vs. JOANNE C. PE BENITO and RANDY T. BALAGUER, Respondents.

FACTS

Petitioner Woodridge School is a private educational institution. Respondents Joanne C. Pe Benito and Randy T. Balaguer were hired as probationary high school teachers, with contracts covering a three-year probationary period. On February 19, 2001, respondents, along with other teachers, presented a manifesto to petitioner raising issues including an alleged NSAT/NEAT anomaly, the lack of due process for a former colleague, the non-issuance of individual contracts, and inconsistent school policies. After a failed confrontation and petitioner’s inaction, respondents filed a formal complaint with the Department of Education, Culture and Sports (DECS) and appeared on television and radio to discuss the alleged anomaly. On February 28, 2001, petitioner placed respondents under preventive suspension for thirty days via memoranda citing grounds such as defamatory remarks, spreading false accusations, and using mass media to malign the school, and required them to explain why they should not be terminated. Respondents filed an illegal suspension case with the NLRC. On March 19, 2001, petitioner issued Notices of Termination effective March 31, 2001, citing the same grounds and adding that respondents failed to meet performance standards for regularization. Respondents amended their complaint to include illegal dismissal. The Labor Arbiter dismissed the complaint, finding the termination justified due to respondents’ failure to submit required teaching documents and their serious misconduct for spreading false accusations via mass media, and validated the preventive suspension. The NLRC affirmed the Labor Arbiter’s decision. The Court of Appeals reversed the NLRC, declaring the preventive suspension illegal, finding respondents’ acts did not constitute serious misconduct, and refusing to sustain petitioner’s claim that respondents failed to qualify for permanent employment due to insufficient evidence. The CA ordered petitioner to pay salaries during the illegal suspension, back wages to Balaguer, and moral and exemplary damages and attorney’s fees to both respondents.

ISSUE

Whether or not the Court of Appeals committed serious error in granting respondents’ petition for certiorari and in setting aside the findings of both the NLRC and the Labor Arbiter.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals. The Court addressed procedural issues first, ruling that the lack of verification and a certificate of non-forum shopping signed by only one respondent were not fatal defects; the rules were relaxed to serve the ends of justice. On the substantive issues, the Court held that the preventive suspension was illegal as the grounds cited (e.g., uniform violations, tardiness, spreading accusations) did not pose a serious and imminent threat to the employer’s life or property as required by law. The Court found respondents’ acts did not constitute serious misconduct. Their manifesto and use of mass media to expose alleged anomalies were acts of concern for the integrity of government exams and the school, done in response to petitioner’s inaction, and not indicative of bad faith or willful intent to cause harm. The Court also ruled that petitioner failed to prove by substantial evidence that respondents did not meet the performance standards for regularization. Their dismissal before the end of their probationary contracts was unjustified. The award of moral and exemplary damages was upheld due to petitioner’s bad faith in effecting the illegal dismissal. The Court modified the CA decision regarding back wages, ordering petitioner to pay Balaguer back wages from April 1, 2001, until the end of his contract in June 2002, and Pe Benito back wages from April 1, 2001, until the end of her contract in June 2001, noting her contract entitled her only to a 10-month salary for actual service rendered.