AI-generated
19

University of the Cordilleras vs. Lacanaria

The petition was granted in part, affirming the dismissal of the professor for serious misconduct while awarding nominal damages for procedural lapses in the termination process. Benedicto F. Lacanaria, an instructor at the University of the Cordilleras, was terminated after making insensitive remarks to a student who collapsed during class. The Court of Appeals had found the dismissal illegal for lack of just cause and due process, but the Supreme Court's resolution indicates that while the misconduct warranted dismissal, procedural defects in the university's process required the award of nominal damages.

Primary Holding

An employee may be validly dismissed for serious misconduct, but the employer's failure to observe procedural due process entitles the employee to nominal damages.

Background

University of the Cordilleras employed Benedicto F. Lacanaria as an Instructor-Associate Professor in the College of Teacher Education beginning June 2005. The dispute arose from Lacanaria's conduct toward a student who experienced a medical emergency during a class presentation, leading to administrative charges of serious misconduct and violation of the Faculty Manual and Code of Ethics for Professional Teachers.

History

  1. Executive Labor Arbiter (DOLE), Dec. 30, 2010 — Dismissed the illegal dismissal complaint but ordered payment of proportionate 13th month pay.

  2. NLRC, Oct. 21, 2011 — Affirmed the ELA decision; denied reconsideration on Jan. 10, 2012.

  3. Court of Appeals, March 18, 2016 — Reversed the NLRC, finding no just cause and denial of due process, ordering reinstatement, backwages, moral and exemplary damages, and attorney's fees.

  4. Supreme Court, Sept. 27, 2021 — Reversed the CA in part, finding serious misconduct warranted dismissal but awarding nominal damages for procedural lapses.

Facts

University of the Cordilleras employed respondent Benedicto F. Lacanaria as an Instructor-Associate Professor in the College of Teacher Education beginning June 2005. On February 25, 2010, a student, Rafael Flores, collapsed during a class creative presentation. Flores reportedly had a persistent cough and later sought medical attention at a hospital. Lacanaria told Flores to sit and at one point said "umupo ka muna dyan, hindi ka pa naman mamamatay," allowed him to go to the clinic but did not promptly attend to him, and later allegedly told him "tae mo!" when Flores tried to report what had happened.

Flores filed a written complaint in early March 2010, supported by classmates’ affidavits and a video. The University issued a Charge Sheet with Notice of Investigation on March 11, 2010, charging Lacanaria with serious misconduct and violation of the Faculty Manual and Code of Ethics for Professional Teachers. The Grievance Committee set hearings for March 30 and April 7, 2010. Lacanaria alleged inadequate notice, claiming text messages and registered mail were delivered less than five days before the hearings, and thus did not attend. The Committee nonetheless took affidavits and recommended dismissal. A Notice of Decision dated May 15, 2010, signed by the VP for Administration, informed Lacanaria of his dismissal; he received it on May 21, 2010. He filed a motion for reconsideration on May 31, 2010, and a later letter withdrawing his intent to resign, but the President denied reconsideration in a Resolution dated June 24, 2010.

Lacanaria filed a complaint for illegal dismissal before the Department of Labor and Employment on June 9, 2010. The Executive Labor Arbiter dismissed his complaint but ordered payment of proportionate 13th month pay on December 30, 2010. The NLRC affirmed the ELA on October 21, 2011, and denied reconsideration on January 10, 2012. Lacanaria then appealed to the Court of Appeals, which reversed the NLRC in a March 18, 2016 Decision. The CA found no just cause, concluded Lacanaria was denied due process due to defective notices, an improper decision signatory, and a de facto denial of teaching load tantamount to preventive suspension, and ordered reinstatement, backwages, moral and exemplary damages, and attorney’s fees. The University filed a Petition for Review on Certiorari under Rule 45 to the Supreme Court, contesting the existence of just cause and the findings on due process.

Issues

  • Procedural Due Process: Whether Lacanaria’s dismissal was tainted with procedural due process defects (notice of hearing, identity of the decision-maker, and related procedural acts).
  • Substantial Evidence: Whether there was substantial evidence to dismiss Lacanaria for serious misconduct or conduct unbecoming of an academician.
  • Entitlement to Reliefs: Given the Court’s findings on procedural and substantive issues, whether Lacanaria is entitled to reinstatement, backwages, and damages.