G.R. No. 175283; March 28, 2008
JACKQUI R. MORENO, Petitioner, vs. SAN SEBASTIAN COLLEGE-RECOLETOS, MANILA, Respondent.

FACTS

Petitioner Jackqui R. Moreno was a permanent full-time faculty member of respondent San Sebastian College-Recoletos (SSC-R). Reports reached SSC-R that Moreno was engaged in unauthorized external teaching at other educational institutions. The school’s Faculty Manual explicitly required full-time faculty to obtain administrative permission before accepting outside teaching loads and to report such assignments. SSC-R conducted a formal investigation, during which Moreno admitted in her written explanations that she taught at Centro Escolar University and College of the Holy Spirit without securing the required written permission. She cited financial necessity as her reason.
A Special Grievance Committee was formed, which found Moreno in violation of school rules. The majority recommended dismissal, while one member suggested suspension. SSC-R adopted the majority recommendation and terminated Moreno’s employment. Moreno filed a complaint for illegal dismissal before the National Labor Relations Commission (NLRC). The Labor Arbiter dismissed her complaint, but the NLRC reversed, finding the dismissal illegal and ordering reinstatement with backwages. SSC-R filed a certiorari petition with the Court of Appeals, which granted it and annulled the NLRC decision, reinstating the Labor Arbiter’s ruling.

ISSUE

Was Moreno’s dismissal from employment for violating the school’s rule on unauthorized external teaching legal?

RULING

Yes, the dismissal was legal. The Supreme Court affirmed the Court of Appeals decision. The core legal principle is that an employer has the inherent right to discipline its employees, including dismissal for just cause, provided by law. Here, the just cause was “serious misconduct” or willful disobedience under Article 282 of the Labor Code. SSC-R’s Faculty Manual and Moreno’s employment contract clearly prohibited outside teaching without prior written permission. These rules were reasonable and necessary to ensure the undivided attention and commitment of full-time faculty to their primary employer, aligning with CHED policies on full-time academic personnel.
Moreno’s repeated and deliberate violations, which she admitted, constituted willful disobedience of lawful company rules. The Court emphasized that the exercise of management prerogative is valid when the rules are reasonable, lawful, and known to the employee, and the penalty is proportionate. Dismissal was the prescribed penalty in the manual for such violations. The Court found the penalty appropriate given the breach of trust and the nature of her duties as a department chairperson. The procedural due process was satisfied as Moreno was given ample opportunity to explain her side through written explanations and a committee investigation before termination. Her plea for leniency based on financial need did not excuse the violation of a clear and reasonable work rule.