Académique Documents
Professionnel Documents
Culture Documents
Facts:
Cheryll Santos Leus, the petitioner was hired by St. Scholasticas College
Westgrove (SSCW), a Catholic educational institution, as a non-teaching
personnel. She got pregnant out of wedlock, so the Directress formally asked her
to explain in writing why she should not be dismissed for engaging in pre-marital
sexual relations and getting pregnant as a result thereof. The same allegedly
constitutes serious misconduct for an employee of a Catholic school. Sr.
Quiambao contended that pursuant to the Manual of Regulation of Private
Schools (MRPS), disgraceful or immoral conduct is an additional ground for
dismissal aside from those provided in the Labor Code. Thus, Leus was
subsequently dismissed.
She filed a complaint for illegal dismissal. The LA upheld the dismissal, holding
that the pregnancy out of wedlock is considered as a disgraceful and immoral
conduct. The NLRC upheld this decision, which was also affirmed by the CA.
They based their decision on the provisions of the Manual of Regulation of
Private Schools.
Issue:
Whether or not the petitioners pregnancy out of wedlock is a valid ground for
termination.
Held:
NO. Pre-marital sexual relations between two consenting adults who have no
impediment to marry each other, and, consequently, conceiving a child out of
wedlock, gauged from a purely public and secular view of morality, does not
amount to a disgraceful or immoral conduct under the MRPS.
The labor tribunals erred in upholding the validity of the petitioners dismissal.
The labor tribunals arbitrarily relied solely on the circumstances surrounding the
petitioners pregnancy and its supposed effect on SSCW and its students without
evaluating whether the petitioners conduct is indeed considered disgraceful or
immoral in view of the prevailing norms of conduct. In this regard, the labor
tribunals respective haphazard evaluation of the evidence amounts to grave
abuse of discretion, which must be rectified.