GR 226727; (April, 2018) (Digest)
G.R. No. 226727 , APRIL 25, 2018
UNIVERSITY OF THE EAST and DR. ESTER GARCIA, Petitioners vs. VERONICA M. MASANGKAY and GERTRUDO R. REGONDOLA, Respondents
FACTS
Respondents Veronica Masangkay and Gertrudo Regondola were regular faculty members and Associate Deans at the University of the East (UE). They submitted three engineering manuals for temporary adoption, certifying under oath that the contents were entirely original and free from plagiarism. UE approved the manuals for student use. Subsequently, UE received complaint letters from the heirs of the authors of established engineering textbooks, alleging that respondents’ manuals contained plagiarized content without permission. UE conducted a thorough investigation, in which respondents participated, and its Board of Trustees ultimately issued a resolution dismissing respondents for cause effective November 26, 2007. Respondents did not appeal their dismissal; instead, they claimed and received their accrued monetary benefits from UE. Almost three years later, on July 20, 2010, they filed a complaint for illegal dismissal.
ISSUE
Whether the Court of Appeals erred in ruling that respondents were illegally dismissed.
RULING
Yes, the Court of Appeals erred. The Supreme Court reversed its decision and dismissed the complaint for illegal dismissal. The Court held that petitioners presented substantial evidence to prove that respondents committed plagiarism, which constitutes serious misconduct and willful breach of trust, both valid causes for termination under Article 282 of the Labor Code. The sworn certifications of originality were false, as the investigation revealed significant copied portions from copyrighted works. This act of academic dishonesty, committed by senior faculty members in an educational institution, fundamentally breached the trust inherent in their positions.
The Court further ruled that the doctrine of stare decisis, invoked by the CA based on a prior case involving a co-author, was misapplied. Stare decisis applies when cases involve identical facts, which was not true here. The co-author’s case involved different procedural postures and evidence. Moreover, respondents’ act of accepting their accrued benefits after dismissal, without protest, effectively constituted a waiver of their right to contest the termination. Their subsequent filing of the illegal dismissal case nearly three years later was an afterthought. Therefore, their dismissal was for a just cause and attended by due process.