GR 89920; (October, 1990) (Digest)
G.R. No. 89920 October 18, 1990
UNIVERSITY OF STO. TOMAS, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and UST FACULTY UNION, respondents.
FACTS
The University of Sto. Tomas dismissed sixteen officers of the UST Faculty Union for alleged grave misconduct and disrespect. This action triggered mass leaves by faculty members, disrupting university operations. The union filed a complaint for illegal dismissal and unfair labor practice. To prevent further disruption, the Secretary of Labor certified the dispute to the NLRC for compulsory arbitration and issued orders directing UST to readmit all faculty members, including the dismissed officers, under the same terms and conditions prevailing prior to the dispute, pending the NLRC’s resolution.
UST sought clarification and subsequently offered “substantially equivalent academic assignments” to the dismissed faculty instead of reinstating them to their actual teaching loads. The union moved for implementation of the Secretary’s orders and for contempt citations. The NLRC issued a resolution directing UST to comply by immediately reinstating or readmitting the faculty members to their former positions or placing them on the payroll. UST filed this petition, arguing that its offer of alternative assignments constituted sufficient compliance with the readmission order.
ISSUE
May a university, pending resolution of a labor dispute by the NLRC, comply with a reinstatement order by granting substantially equivalent academic assignments instead of actual reinstatement to the dismissed employees’ former positions?
RULING
No. The Supreme Court ruled that the Secretary of Labor’s orders for readmission “under the same terms and conditions” unequivocally meant actual reinstatement to the faculty members’ former teaching positions or, at the very least, reinstatement to the payroll. The legal logic is grounded in the purpose of reinstatement pending litigation, which is to restore the status quo ante and prevent the aggrieved party from suffering further prejudice during the dispute’s pendency. Offering different assignments, even if arguably equivalent, does not satisfy this legal requirement as it alters the pre-dismissal employment conditions.
The Court acknowledged the university’s operational concerns but held that contracts with replacement professors cannot override the statutory right to reinstatement. However, applying equitable principles to avoid disrupting students during ongoing semester finals, the Court modified the NLRC’s order. It directed UST to effect the actual reinstatement of the sixteen faculty members to their former teaching loads at the start of the next semester. Until that actual reinstatement, the employees were entitled to full back wages and benefits. The petition was dismissed, and the temporary restraining order was lifted.