Buena, Marco Antonio

Candolita, Therese Anne

Masanguid, Remmon
Melendrez, Marie Florienne
Santos, Nix
I- Wigmore
! "une #!$%
Woodridge School vs. Benito and Balaguer
&'R' No' $(!#%!, )*! SCRA $(%, +,cto-er #., #!!/0
FACTS
1etitioner Woodridge School is a 2ri3ate educational institution located at Wood4inds
5illage, Molino (, Bacoor, Ca3ite' Res2ondents "oanne C' 1e Benito and Rand6 T'
Balaguer 4ere hired as 2ro-ationar6 high school teachers e77ecti3e "une $../ and "une
$..., res2ecti3el6' Their contracts o7 em2lo6ment co3ered a three +0 6ear 2ro-ationar6
2eriod'
,n Fe-ruar6 $., #!!$, res2ondents, together 4ith t4ent6 other teachers, 2resented to
2etitioner 4ith a Mani7esto 8sta-lishing Rele3ant Issues Concerning the School raising
3arious issues' Among these issues 4ere the NSAT9N8AT anomal6, the teacher:s right to
due 2rocess, issuance o7 indi3idual contracts, and non-clear-cut school 2olicies' A
con7rontation -et4een the school administrators and the concerned teachers 4as held, -ut
no settlement 4as arri3ed at'
;ue to the 7ailure o7 the 2arties to resol3e the issues, res2ondents 7iled a 7ormal com2laint
against the 2etitioner 4ith the ;e2artment o7 8ducation, Culture, and S2orts +;8CS0
re<uesting the latter to underta=e a 7ormal in3estigation, institute a22ro2riate charges, and
im2ose 2ro2er sanctions against 2etitioner' ;uring the 2endenc6 o7 the ;8CS case,
res2ondents a22eared on tele3ision and s2o=e o3er the radio on the alleged NSAT9N8AT
anomal6'
,n Fe-ruar6 #/, #!!$, 2etitioner sent t4o se2arate Memoranda to res2ondents 2lacing
them under 2re3enti3e sus2ension 7or a 2eriod o7 thirt6 da6s, 4hich 2rom2ted
res2ondents to commence an action 7or illegal sus2ension -e7ore the National >a-or
Relations Commission +N>RC0'
,n March $., #!!$, 2etitioner issued res2ondents their Notice o7 Termination, each to
ta=e e77ect similarl6 on March $, #!!$' Res2ondents then amended their initial
com2laint to include illegal dismissal'
,n No3em-er #., #!!$, >a-or Ar-iter 5icente R' >a6a4en rendered a ;ecision
dismissing the com2laint' ?e concluded that the termination o7 the res2ondents:
2ro-ationar6 em2lo6ment 4as @usti7ied -ecause o7 their 7ailure to su-mit 3ital teaching
documents, such as lesson 2lans and su-@ect s6lla-i' The >a-or Ar-iter 7ound res2ondents
guilt6 o7 serious misconduct 4arranting their dismissal 7rom ser3ice -ecause o7
maliciousl6 s2reading 7alse accusations against the school through mass media, 4hich
made them un7it to remain in the school:s roster o7 teachers' The >a-or Ar-iter also
3alidated the 2re3enti3e sus2ension o7 res2ondents'
,n a22eal to the N>RC, the Commission a77irmed the >a-or Ar-iter:s dis2osition' The
Commission concluded that res2ondents: acts, ta=en together, constitute serious
misconduct, 4arranting their dismissal 7rom ser3ice' Aggrie3ed, res2ondents ele3ated the
matter to the CA' The CA granted the 2etition and set aside the N>RC ruling a decision'
The a22ellate court declared the 2re3enti3e sus2ension o7 res2ondents in3alid -ecause it
4as -ased on grounds that do not 2ose a serious threat to the li7e or 2ro2ert6 o7 the
em2lo6er or o7 the 4or=ers' The CA concluded that res2ondents: acts do not constitute
serious misconduct'
The a22ellate court li=e4ise re7used to sustain 2etitioner:s contention that res2ondents
7ailed to <uali76 7or 2ermanent em2lo6ment, as there 4as no su77icient e3idence to 2ro3e
the same' The a22ellate court em2hasized that -ecause res2ondents are 2ro-ationar6
em2lo6ees, legal 2rotection extends onl6 to the 2eriod o7 their 2ro-ation' The dismissal
-reached their 2ro-ationar6 em2lo6ment, and -eing tainted 4ith -ad 7aith, the court
u2held the a4ard o7 moral and exem2lar6 damages'
LEGAL ISSUES
$' W,N the 2re3enti3e sus2ension and su-se<uent dismissal o7 the res2ondents 4as
3alidl6 made
#' W,N the a4ard o7 moral and exem2lar6 damages ha3e su77icient -asis to su22ort
the a4ard
HOLI!G
As to the issue on the res"ondents# dis$issal and "reventive sus"ension% the
Su"re$e Court ruled that these &ere not validl' $ade.
The contro3ers6 re3ol3es onl6 during the res2ondents: 2ro-ationar6 em2lo6ment' The
ser3ices o7 an em2lo6ee hired on 2ro-ationar6 -asis ma6 -e terminated 4hen he 7ails to
<uali76 as a regular em2lo6ee in accordance 4ith reasona-le standards made =no4n -6
the em2lo6er to the em2lo6ee at the time o7 his engagement' Con3ersel6, the em2lo6er is
not 2recluded 7rom terminating the 2ro-ationar6 em2lo6ment i7 the em2lo6ee 7ails to
<uali76 on the standards made =no4n and gi3en that it is made 4ithin @usti7ia-le grounds'
In the case at -ar, the notices o7 termination sent -6 the em2lo6er to the res2ondents
stated that the6 7ailed to <uali76 as regular em2lo6ees -ut did not gi3e the details o7 the
said A7ailure to <uali76B and the standards not met -6 the res2ondents' Thus, it is
s2eculated that the conclusion o7 the 2etitioner is -ased merel6 on the grounds o7 uttering
de7amator6 remar=s against the school and the school 2rinci2al, 7ailure to re2ort 7or 4or=
7or t4o or three times, going to class 4ithout 4earing 2ro2er uni7orm, dela6 in the
su-mission o7 class records and non-su-mission o7 class s6lla-i' Still, the 2etitioners
7ailed to su22ort the claims -6 2resenting related documentar6 e3idence such as
e3aluation re2orts there-6 ma=ing the dismissal in3alid'
In the same 4a6, the 2re3enti3e sus2ension o7 the res2ondents: is also in3alid' The la4
clearl6 states that the em2lo6er can onl6 2ut the em2lo6ee under 2re3enti3e sus2ension i7
the latter:s continued em2lo6ment 2oses a serious and imminent threat to the li7e or
2ro2ert6 o7 the em2lo6er or o7 his co-4or=ers' The grounds 2ro3ided -6 the 2etitioners
do not, in an6 4a6 2ose threat to li7e and 2ro2ert6 o7 the school, the teachers or o7 the
students and their 2arents' Thus, the said 2re3enti3e sus2ension is illegal'
The res2ondents also cannot -e dismissed on the ground o7 serious misconduct' In
determining misconduct, it is not su77icient that the act or conduct com2lained o7 has
3iolated some esta-lished rules or 2olicies' It is e<uall6 im2ortant and re<uired that the
act or conduct must ha3e -een 2er7ormed 4ith 4rong7ul intent'
The 1etitioner anchored its im2utation o7 serious misconduct 2rinci2all6 on the
res2ondents: mo3e o7 2resenting to 2etitioner a mani7esto, setting 7orth the issues the6
4anted the school to address' The tenor o7 the mani7esto indicated good 7aith, as the
teachers, in 7act, ex2ressl6 stated that their ultimate o-@ecti3e 4as not to 2ut the school
do4n, -ut to 4or= 7or some changes 4hich 4ould -e -ene7icial to the students, teachers,
the school and the countr6 as a 4hole' The totalit6 o7 the acts o7 the res2ondents cannot
-e characterized as misconduct under the la4 and not enough to result to dismissal' The
7act that the 2etitioners in7ormed the res2ondents o7 their su-standard 2er7ormance onl6
a7ter the ex2ose o7 the NSAT9N8AT anomal6 su22orts the idea that the sus2ension and
dismissal 7rom ser3ice o7 the res2ondents are tainted 4ith -ad 7aith'

(es% there is enough )asis to su""ort the a&ard o* $oral and e+e$"lar' da$ages.
A dismissed em2lo6ee is entitled to moral damages 4hen the dismissal is done in -ad
7aith or 7raud, or is done in a manner contrar6 to good morals, customs or 2u-lic 2olic6'
,n the other hand, a dismissed em2lo6ee is entitled to exem2lar6 damages i7 the
dismissal is made in a deli-erate, o22ressi3e or male3olent manner' A4arding o7 said
damages cannot -e @usti7ied solel6 u2on the 2remise that the em2lo6er 7ired his em2lo6ee
4ithout @ust cause or due 2rocess' The additional 7acts should -e 2leaded and 2ro3en that
the dismissal 4as indeed done in -ad 7aith and 4ith 7raud, and that social humiliation,
4ounded 7eelings and gra3e anxiet6 resulted 7rom it'
The Su2reme Court 7inds there is no <uestion that -oth res2ondents are entitled to the
a4ard o7 moral and exem2lar6 damages, as the act o7 dismissal 4as tainted 4ith -ad 7aith
on the 2art o7 2etitioner 4ho e77ecti3el6 exerted 2ressure to silence the res2ondents
regarding their legitimate grie3ances against the school as su77icientl6 esta-lished in the
records' The 2etitioner:s actuations ha3e tarnished the 2ro7essional integrit6 o7 the
res2ondents and di3ided the rest o7 the 7acult6 mem-ers on the contro3ers6' For such
un@usti7ied acts in relation to the N8AT9NSAT contro3ers6 that resulted to loss, 2re@udice
and damage to res2ondents, the Su2reme Court 7inds 2etitioner lia-le 7or moral and
exem2lar6 damages'