G.R. No. 83268 . January 31, 1989.
JOSEFINA B. CALLANGAN, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and GREGORIO ARANETA UNIVERSITY FOUNDATION, respondents.

FACTS

Petitioner Josefina Callangan was a faculty member of Gregorio Araneta University Foundation (GAUF) since 1971. On June 8, 1981, she was designated as Director for Non-Academic Affairs for a fixed two-year term ending June 8, 1983. Her appointment letter stipulated that if her designation was not renewed, she would be reverted to her previous status as a full-time faculty member. In October 1982, administrative charges were filed against her. An Ad Hoc Committee found her guilty and recommended dismissal on June 14, 1983. Despite her appeal to the Board of Trustees, her services as Director were terminated on June 30, 1983, upon the expiration of her term. The university also abolished the position as part of a retrenchment program.
On November 28, 1983, after executing a waiver stating she would not file a damage suit if exonerated, the Board of Trustees exonerated her from all charges and recommended her reinstatement as a faculty member. However, she was only given teaching assignments in April 1984. She subsequently filed a complaint for backwages and damages. The Labor Arbiter ruled in her favor, ordering payment of salaries as Director from her dismissal until reinstatement and damages. The NLRC reversed this decision, dismissing her complaint, ruling her termination was justified due to the expiration of her fixed-term contract and the valid abolition of her office.

ISSUE

Whether the NLRC committed grave abuse of discretion in dismissing Callangan’s complaint, thereby denying her right to backwages and damages arising from the delay in her reinstatement to a faculty position following her exoneration.

RULING

The Supreme Court granted the petition, finding the NLRC’s reversal a grave abuse of discretion. The legal logic centers on the explicit terms of Callangan’s appointment and the consequences of her exoneration. Her appointment as Director contained a clear stipulation for reversion to her former faculty position if the term was not renewed. The Board of Trustees’ November 1983 resolution exonerating her and ordering her immediate reinstatement as a faculty member crystallized this contractual right. Consequently, her entitlement was to her faculty salary from the point her directorship ended, not the higher director’s salary as the Labor Arbiter ordered. The Court modified the Arbiter’s decision accordingly.
The delay in implementing the reinstatement order from November 1983 to April 1984 was unjustified. The waiver she signed, promising not to sue for damages upon exoneration, was premised on the assumption of immediate reinstatement. It did not bar a claim for compensation for the period of unlawful joblessness and the attendant anxiety caused by the delay. Thus, she was entitled to backwages as a faculty member for the period she was not reinstated and moderate damages. The NLRC’s failure to recognize these rights constituted a denial of substantial justice. The Court set aside the NLRC decision and ordered GAUF to pay Callangan her faculty salaries from June 8, 1983, to April 1984, minus amounts already received, and P5,000 in damages.