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Raymond A. Son, et al. v. University of Santo Tomas, et al., G.R. No. 211273 | 2018

Case Digest: G.R. No. 211273 | April 18, 2018

Raymond A. Son, Raymond S. Antiola, and Wilfredo E. Pollarco vs. University of Santo Tomas, et al.

Ponente: Justice Del Castillo

Nature of the Petition

This Petition for Review on Certiorari challenges the September 27, 2013 Decision of the Court of Appeals (CA) in CA-G.R. SP No. 128666, which reversed the National Labor Relations Commission (NLRC) Decisions dated August 10, 2011, October 30, 2012, and January 22, 2013. The CA reinstated the March 26, 2012 NLRC Decision and denied the petitioners’ Motion for Reconsideration on January 29, 2014.

Court Ruling

The Supreme Court DENIED the petition, affirming the Court of Appeals Decision and Resolution in full.

Key Doctrines

  • The requirement of a master's degree for tertiary-level educators is reasonable and necessary to uphold the quality of education.

  • Educational institutions serve public interest, and the government has the authority to ensure that only qualified teachers with adequate academic knowledge and teaching skills are employed.

  • Government regulation in education is essential for protecting both students and the public from underqualified faculty members.

  • Teachers may be required to possess postgraduate degrees or pass examinations before securing employment in higher education institutions.

Case Background

The primary issue was whether the petitioners were illegally dismissed from their teaching positions at the UST Colleges of Fine Arts and Design and Philosophy.

Employment Terms and Master's Degree Requirement

  • The petitioners were probationary faculty members, subject to the condition that they must obtain a master's degree within the probationary period to qualify for tenured status.

  • Although they enrolled in graduate programs, they failed to complete their master's degrees within the stipulated timeframe.

  • Despite this, they continued teaching beyond the prescribed period.

CHED Memorandum and Faculty Dismissals

  • On March 3, 2010, CHED Chairman Emmanuel Angeles issued a memorandum mandating strict implementation of minimum qualifications for faculty members teaching undergraduate courses.

  • UST enforced this directive, discontinuing the reappointment of faculty members who failed to meet the master’s degree requirement.

  • Faculty members facing dismissal were allowed to appeal if they were close to completing their degrees, but the petitioners did not submit appeals.

  • They argued that their tenure rights were protected under the Collective Bargaining Agreement (CBA) despite their failure to meet CHED's academic qualification criteria.

Legal Findings

  1. The court ruled that the petitioners were not illegally dismissed, as they did not meet the qualification standards for undergraduate teaching positions.

  2. The tenure provision in the CBA contradicts the 1992 Revised Manual of Regulations for Private Schools and is therefore null and void.

  3. The petitioners were given ample time to comply but failed to obtain their required master's degrees.

  4. The Supreme Court upheld the dismissal, emphasizing that educators are expected to meet regulatory standards.

Conclusion

The Supreme Court confirmed that the petitioners’ failure to meet academic requirements justified their dismissal. Educational institutions have a legal and ethical duty to ensure faculty members are qualified to teach in their respective fields.

For more details, refer to the full ruling at the .

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