International School vs. ISAE, February 5, 2014

Facts:
Santos is a full-time Spanish language teacher since she was hired by the International School in 1978. After coming back from a leave of absence, she agreed to teach one Spanish class and four Filipino class.
 
Santos was observed by the School’s high school administrators in her conduction of classes. The result of the Classroom Standards Evaluation Form was poor wherein it indicated that Santos needed improvement in conducting classes.
 
After a series of classroom observations, Santos continued to receive poor feedbacks from the school’s administrators. Eventually, Principal Peter Loy required Santos to undergo the remediation phase of the evaluation process through a Professional Growth Plan.
 
In a letter dated May 29, 1997, McCauley informed Santos that he was adopting the recommendation of the investigation committee that Santos’s employment from the School cannot be continued. According to McCauley, the committee found that the numerous consultations of Santos with her supervisors for the last three school years did not result in any appreciable improvement on her part. Given that Santos was duly licensed to teach Filipino, McCauley stated that the committee could not accept her claim that she was ill-equipped to teach the language. McCauley then told Santos that her employment with the School would cease effective June 7, 1997.

Issue;
Whether Evangeline Santos was illegally dismissed.

Held:
​No. The International School had sufficiently proved the charge of gross inefficiency, which warranted the dismissal of Santos from the School. She appeared to lack the necessary skills, in-depth knowledge, and expertise to teach the Filipino language at the standards required by the School.
 
Since Santos was validly dismissed from her employment, she would not ordinarily be entitled to separation pay. However, applying the principle of social justice according to the equities of the case (PLDT v. NLRC), the Court finds equitable and proper the award of separation pay in favor of Santos in view of the length of her service with the School.