G.R. No. L-75583. November 8, 1988.
GREGORIO ARANETA UNIVERSITY FOUNDATION, petitioner, vs. ANTONIO J. TEODORO and NATIONAL LABOR RELATIONS COMMISSION, respondents.

FACTS

Private respondent Antonio J. Teodoro was employed by petitioner Gregorio Araneta University Foundation (GAUF) starting in 1954, rising through the ranks to become Vice President and Treasurer by 1981. His appointment was extended on an ad interim basis until May 31, 1983, after which the Board of Trustees did not re-elect him. Teodoro filed a complaint for illegal dismissal, claiming his termination was due to his submission of a critical “insight report” to the founder’s daughters, alleging irregularities within GAUF. The Labor Arbiter ruled in his favor, awarding backwages, accrued leave, gratuity pay, and damages. The National Labor Relations Commission (NLRC) affirmed the monetary awards but deleted the damages and attorney’s fees.

ISSUE

The primary issues were (1) whether the NLRC had jurisdiction over the case, and (2) whether Teodoro was illegally dismissed and entitled to the awarded benefits.

RULING

The Supreme Court affirmed the NLRC decision. On jurisdiction, the Court held the NLRC properly exercised jurisdiction. Petitioner’s reliance on cases involving intracorporate disputes over the validity of board elections was misplaced. Here, no such intracorporate controversy existed; the core issue was the termination of employment, squarely within the labor tribunal’s jurisdiction under the Labor Code. On the merits, the Court found Teodoro was a regular employee, having served for nearly 29 years in positions necessary to GAUF’s business, thus entitled to security of tenure. However, the Court agreed with the NLRC’s finding that Teodoro was not entirely without fault. His unsubstantiated “insight report,” for which he later apologized, provided a valid cause for the non-renewal of his appointment. Consequently, while the dismissal was not entirely unjustified to warrant reinstatement, his length of service entitled him to the awarded backwages and gratuity pay as a form of separation benefit. The disallowance of moral and exemplary damages and attorney’s fees was sustained, as there was no showing of unlawful withholding of wages or bad faith in the termination.