G.R. No. 187226 ; January 28, 2015
Cheryll Santos Leus, Petitioner, vs. St. Scholastica’s College Westgrove and/or Sr. Edna Quiambao, OSB, Respondents.

FACTS

Petitioner Cheryll Santos Leus was hired in May 2001 as a non-teaching personnel (Assistant to the Director of the Lay Apostolate and Community Outreach Directorate) by respondent St. Scholastica’s College Westgrove (SSCW), a Catholic educational institution. In 2003, petitioner, unmarried, conceived a child out of wedlock. Upon learning of the pregnancy, SSCW’s Directress, Sr. Edna Quiambao, advised petitioner to resign. Petitioner refused. SSCW then directed petitioner to explain why she should not be dismissed for engaging in pre-marital sexual relations resulting in pregnancy, which it considered serious misconduct and conduct unbecoming of an employee of a Catholic school. Petitioner explained she was unaware of any school policy classifying pregnancy out of wedlock as serious misconduct and requested a copy of such policy. SSCW responded that, pending a “Support Staff Handbook,” it followed the 1992 Manual of Regulations for Private Schools (1992 MRPS), citing “disgraceful or immoral conduct” under Section 94(e) as a ground for dismissal. Petitioner, through counsel, argued that pre-marital sex between consenting adults without legal impediment to marry, who later married, did not constitute “disgraceful or immoral conduct” or “serious misconduct.” SSCW maintained its position, emphasizing its right as a Catholic institution to uphold Church teachings and that petitioner’s position made her a role model. Petitioner adopted her counsel’s letter as her explanation. Consequently, SSCW terminated petitioner’s employment on June 11, 2003, on the ground of serious misconduct, stating the scandal of pregnancy out of wedlock counteracted the moral principles SSCW upholds. Petitioner filed an illegal dismissal complaint. The Labor Arbiter dismissed the complaint, ruling petitioner’s conduct was “disgraceful and immoral.” The NLRC affirmed, citing Section 94(e) of the 1992 MRPS. The Court of Appeals denied petitioner’s certiorari petition, upholding the NLRC and stating the 1992 MRPS, as a special statute, prevails over the Labor Code, and that petitioner’s conduct was scandalous per se given her work environment in a Catholic school.

ISSUE

Whether petitioner’s conduct (engaging in pre-marital sexual relations resulting in pregnancy out of wedlock, though she later married the father) constitutes a valid ground for her dismissal from employment by a Catholic educational institution.

RULING

No. The Supreme Court granted the petition, reversed the Court of Appeals Decision and Resolution, and declared petitioner’s dismissal illegal. The Court ruled that petitioner’s dismissal was not based on a just or authorized cause. The Court held that while the 1992 MRPS applies to termination of private school personnel, the ground “disgraceful or immoral conduct” must still be interpreted in light of the Labor Code and prevailing jurisprudence. The Court found that petitioner’s single act of pre-marital sexual intercourse with her boyfriend (who later became her husband) and subsequent pregnancy did not constitute “disgraceful or immoral conduct” warranting dismissal. The Court emphasized that morality is not confined to sexual norms alone and must be considered in the context of the employee’s duties and the employer’s work rules. The Court noted SSCW failed to present any written rule or policy expressly prohibiting pre-marital sexual relations and classifying it as a ground for dismissal. Furthermore, the Court ruled that SSCW failed to substantiate its claim that petitioner’s conduct resulted in a scandal that eroded the school’s moral principles, as no evidence was presented showing how her private act affected her work or the school environment. The act was a private, consensual activity that did not involve abuse of her position. Therefore, her dismissal was illegal. The Court ordered SSCW to reinstate petitioner and pay her full backwages, allowances, and other benefits, or separation pay if reinstatement is not feasible, plus attorney’s fees.