G.R. No. 75093. February 23, 1990.
DELIA R. SIBAL, petitioner, vs. NOTRE DAME OF GREATER MANILA and NATIONAL LABOR RELATIONS COMMISSION, respondents.

FACTS

Petitioner Delia R. Sibal was employed as a school nurse by Notre Dame of Greater Manila starting in 1973. Her original employment terms required work only during the ten-month school year, with full pay for twelve months, and she was not required to report during summer and Christmas vacations. In 1980, under a new director, Fr. Pablo Garcia, she was ordered to report for work during the summer. She objected, citing her contract. During the 1981-1982 school year, she was additionally assigned to teach health subjects to 19 sections due to a teacher shortage but received no extra compensation, unlike other teachers. Her requests for discussion on unpaid vacation pay and teaching compensation were ignored.
In April 1982, Fr. Garcia again ordered her to report for summer work. She reiterated her objections and her unmet monetary claims. On June 14, 1982, the school opening day, immediately after being served a summons for her labor complaint regarding unpaid benefits, she was handed a termination letter effective immediately. She then amended her complaint to include illegal dismissal and unfair labor practice.

ISSUE

The primary issue is whether petitioner’s dismissal was legal and whether she is entitled to reinstatement, backwages, compensation for extra teaching duties, and moral damages.

RULING

The Supreme Court ruled for the petitioner, finding her dismissal illegal. The legal logic is anchored on the absence of a just or authorized cause for termination and a blatant violation of due process. Her refusal to perform summer work was justified as it constituted a unilateral change in her employment terms to which she did not consent. The dismissal, effected on the very day she pursued her legal claims, was retaliatory and constituted an unfair labor practice, penalizing her for asserting her rights.
The Court emphasized that while management has prerogatives, these must be exercised without abuse of discretion and in good faith. The series of discriminatory acts—withholding vacation pay, denying extra compensation for teaching duties performed under compulsion, undercomputing her 13th month pay, and the summary dismissal—collectively established bad faith. This justified the award of moral damages under Article 1701 of the Labor Code and relevant Civil Code provisions on human relations. Consequently, the NLRC decision was set aside. The school was ordered to reinstate Sibal without loss of seniority rights, pay three years of backwages, compensate her for the extra teaching work, and pay moral damages, with the NLRC to determine the exact amount.