G.R. No. 76752 ; January 12, 1990
ST. MARY’S COLLEGE (TAGUM, DAVAO), SR. JACINTA DE BELEN, R.V.M., SR. MILAGROS SEALONGO, R.V.M. and JOSEFINA LLEDO, R.V.M., petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, ASSOCIATED LABOR UNION (TUCP), MIGUELITA LUBIANO, ELENA ODILAO, ROSALINDA FRANCISQUETE, LOUELLA DE BORJA, DELIA DE LA CRUZ and AIDA PERALTA, respondents.

FACTS

The petitioners are the directress, principal, and cashier of St. Mary’s College. The private respondents are faculty members. In April 1982, the private respondents authored and circulated a “Manifesto” within the school, accusing the individual petitioners of various acts, including forcing teachers to waive benefits, blacklisting teachers, terminating employment without evaluation, and obstructing the organization of a teachers’ union. The Manifesto demanded the replacement of the petitioners. Upon investigation and admission of authorship by the private respondents, the school terminated the services of three for gross insubordination and serious disrespect and did not renew the probationary contracts of the other three.
The private respondents, with the Associated Labor Union, filed a complaint for illegal dismissal and unfair labor practice. During proceedings, the parties failed to settle and submitted position papers. Petitioners attached a letter from 77 faculty members disclaiming authorization for the Manifesto’s authors and a certification from 68 teachers stating they freely decided to form a Faculty Association, not a union, without administrative interference. Private respondents submitted certificates of good character. Labor Arbiter Potenciano Canizares found petitioners guilty of unfair labor practice, ordering reinstatement with backwages, a decision affirmed by the NLRC except for the deletion of moral damages.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the finding of unfair labor practice and illegal dismissal against the petitioners.

RULING

The Supreme Court reversed the NLRC decision and dismissed the complaint. The Court held that petitioners were not deprived of due process, as the parties were given an opportunity to be heard and submitted their position papers for resolution, which satisfies procedural requirements. On the substantive issue, the Court found the NLRC’s finding of unfair labor practice to lack substantial evidentiary support. The evidence showed that 68 teachers certified there was no interference with their right to self-organization, and 77 teachers, including six allegedly blacklisted, denied the charges. This overwhelming disavowal from the majority of the faculty indicated private respondents lacked the requisite support for union organizing, negating any motive for petitioners to commit unfair labor practices. Conversely, the private respondents’ admitted authorship of the derogatory Manifesto, which ridiculed school authorities and disrupted order, constituted gross misconduct, providing a just cause for termination of their employment. The NLRC’s decision was therefore not supported by substantial evidence.