GR 222317; (January, 2018) (Digest)
G.R. No. 222317 . January 24, 2018.
ST. PAUL COLLEGE, PASIG, and SISTER TERESITA BARICAUA, SPC, Petitioners, vs. ANNA LIZA L. MANCOL and JENNIFER CECILE S. VALERA, Respondents.
FACTS
Respondents Anna Liza L. Mancol and Jennifer Cecile S. Valera were pre-school teachers at petitioner St. Paul College, Pasig (SPCP). In May 2010, Mancol filed a leave for a fertility check-up in Canada. Upon her return, she was barred from teaching, entering her classroom, and performing her duties, and was required to explain her allegedly unapproved leave. Valera took a leave for scoliosis surgery in April 2010. Upon her intended return, she was advised to file a sick leave for the entire school year or face reassignment, and was required to submit a liability waiver and a physician’s fitness certification. Both respondents alleged these acts constituted constructive dismissal.
The respondents also filed monetary claims for unpaid overtime, holiday, and rest day premiums. They alleged they worked daily beyond their official hours without compensation, including during lunch breaks and on numerous weekends for school events, and were required to take on additional teaching loads without extra pay based on an inapplicable DepEd order.
ISSUE
Whether the Court of Appeals correctly affirmed the finding of the Labor Arbiter and the NLRC that respondents were constructively dismissed and entitled to their monetary claims.
RULING
Yes, the Supreme Court denied the petition and affirmed the findings of constructive dismissal and entitlement to monetary claims. On constructive dismissal, the Court held that the petitioners’ actions constituted an involuntary resignation due to unbearable working conditions. For Mancol, being barred from her teaching duties after her leave was a clear demotion in rank and a denial of her status as a teacher. For Valera, forcing her to take a year-long leave or accept a detrimental reassignment under onerous conditions amounted to a forced choice equivalent to dismissal. The employer failed to prove these acts were for valid and authorized causes.
Regarding the money claims, the Court ruled that the respondents sufficiently substantiated their allegations of uncompensated work. The detailed enumeration of specific dates and events for weekend work, along with the practice of unpaid extended daily hours and lunchtime meetings, established that these activities were work-related and under the employer’s control. The employer’s failure to disprove these claims with countervailing evidence, such as payroll or time records, led to the conclusion that the claims were valid. The awards for overtime, holiday, and service incentive leave pay were thus upheld.