G.R. No. 224170 , June 10, 2020
University of St. La Salle, Petitioner, vs. Josephine L. Glaraga, Maricar C. Manaay, Leo G. Lozana, Queenie M. Jarder, Erwin S. Pondevida, Arlene T. Conlu, Jo-Ann P. Saldajeno, Tristan Julian J. Teruel, Jean C. Argel and Sheila Cordero, Respondents.

FACTS

Petitioner University of St. La Salle engaged respondents as probationary full-time faculty members. Beginning the first semester of 2010-2011, their teaching loads were reduced, and they were engaged as probationary part-time faculty members due to a decline in enrollment, a arrangement petitioner stated was temporary. Their engagements were covered by Documents of Agreement for five-month periods containing a clause stating the contract covered only the specific period and renewal would be based on performance evaluation and other criteria. In the summer and first semester of 2011, respondents were not offered any teaching load or new agreements. They filed a complaint for illegal dismissal. The Labor Arbiter granted the complaint, finding dismissal for an authorized cause (likely redundancy) but without procedural due process, awarding separation pay and nominal damages. The NLRC reversed, declaring that the complainants’ probationary employment simply expired. The Court of Appeals reversed the NLRC and reinstated the Labor Arbiter’s decision with modification, increasing the nominal damages.

ISSUE

1. Whether the Court of Appeals erred in finding that respondents were illegally terminated from employment instead of declaring that their term merely expired.
2. Whether the Court of Appeals erred in awarding money claims and nominal damages to the respondents.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals.
1. On the first issue, the Court held that the probationary period of teachers is for a maximum of three years, even if they render service under fixed short-term contracts, unless a shorter period is expressly adopted. The vagueness in the parties’ documents of agreement justified the presumption of a three-year probationary period. Since the non-renewal of respondents’ fixed-term contracts occurred during this three-year probationary period, it amounted to a dismissal, not a mere expiration of term. The allegations and evidence indicated the dismissal was due to redundancy, an authorized cause under the Labor Code.
2. On the second issue, the Court affirmed the award of separation pay due to the dismissal being for an authorized cause (redundancy). It also affirmed the award of nominal damages due to petitioner’s failure to comply with the procedural requirement of prior notice under the Labor Code.