The Supreme Court ruled that private educational institutions can require a master’s degree as a condition for granting permanent full-time faculty status. This decision affirms the right of schools to set academic standards and ensures that educators meet specific qualifications for tenure. It clarifies that institutions can enforce these requirements, even if an employee has completed a probationary period with satisfactory performance.
Academic Achievement vs. Institutional Standards: Can a College Deny Tenure?
The case of Jocelyn Herrera-Manaois v. St. Scholastica’s College revolves around whether St. Scholastica’s College (SSC) legally denied Jocelyn Herrera-Manaois a permanent teaching position due to her failure to obtain a master’s degree. Manaois, an alumna of SSC with a Bachelor of Arts in English, was hired as a probationary full-time faculty member. During her probationary period, she was expected to complete her Master of Arts in English Studies. Despite extensions, Manaois did not finish her master’s degree, leading SSC to not renew her contract. She then filed a complaint for illegal dismissal.
The Labor Arbiter initially ruled in favor of Manaois, stating that the requirement to finish the master’s degree was not adequately communicated to her at the start of her engagement. The National Labor Relations Commission (NLRC) upheld this decision. However, the Court of Appeals (CA) reversed the NLRC’s judgment, finding that Manaois was aware of the master’s degree requirement and that SSC acted within its rights by not renewing her contract. The Supreme Court was then tasked to determine whether completing a master’s degree is a valid requirement for tenure in a private educational institution.
The Supreme Court upheld the Court of Appeals’ decision, emphasizing the rights of private educational institutions to set academic standards for their faculty. The Court referenced Article 281 of the Labor Code, which pertains to probationary employment. It states that an employee’s services may be terminated if they fail to meet reasonable standards made known at the time of engagement. This principle is crucial in understanding the balance between employee rights and employer prerogatives during a probationary period.
Art. 281. Probationary employment. Probationary employment shall not exceed six (6) months from the date the employee started working, unless it is covered by an apprenticeship agreement stipulating a longer period. The services of an employee who has been engaged on a probationary basis may be terminated for a just cause or when he fails to qualify as a regular employee in accordance with reasonable standards made known by the employer to the employee at the time of his engagement. An employee who is allowed to work after a probationary period shall be considered a regular employee.
Building on this principle, the Court found that Manaois was indeed aware of the requirement to obtain a master’s degree. Her application letter, subsequent correspondences with SSC, and the SSC Faculty Manual all indicated this requirement. The Court noted that the employment contract incorporated the rules and regulations in the SSC Faculty Manual, which explicitly stated the criteria for permanency, including the completion of a master’s degree.
CRITERIA FOR PERMANENCY
- The faculty member must have completed at least a master’s degree.
- The faculty member must manifest behavior reflective of the school’s mission-vision and goals.
- The faculty member must have consistently received above average rating for teaching performance as evaluated by the Academic Dean, Department Chair/Coordinator and the students.
- The faculty member must have manifested more than satisfactory fulfillment of duties and responsibilities as evidenced by official records especially in the areas of: x x x
- The faculty member must manifest awareness of and adherence to the school’s code of ethics for faculty.
- The faculty member must be in good physical health and manifest positive well being.
The Court clarified the interpretation of the SSC Faculty Manual regarding the minimum requirements for the rank of instructor. It stated that the requirements for the rank of instructor referred to how instructors are ranked, not to the qualifications required to attain permanency. Therefore, the sections on both permanency and the ranking of an instructor must be read together to determine the academic qualifications for a permanent full-time faculty member.
Moreover, the Supreme Court emphasized that even satisfactory performance during the probationary period does not guarantee permanent employment. The probationer must fulfill the reasonable standards set for permanent employment. In line with academic freedom, educational institutions have the right to set standards for their teachers and determine whether those standards have been met. The final decision to re-hire a probationer lies with the employer, reinforcing the institution’s autonomy.
The Court also noted that private educational institutions must adhere to the standards set by government agencies such as the Department of Education (DepEd) and the Commission on Higher Education (CHED). The 1992 Manual of Regulations for Private Schools, applicable at the time of Manaois’s engagement, provides conditions for probationary employment and the minimum qualifications for faculty members. Section 44 of this manual specifies that for undergraduate courses, teachers should hold a master’s degree in their major field.
Section 44. Minimum Faculty Qualifications. The minimum qualifications for faculty for the different grades and levels of instruction duly supported by appropriate credentials on file in the school shall be as follows:
x x x x
c. Tertiary
(1) For undergraduate courses, other than vocational:
Because private educational institutions in the tertiary level may extend “full-time faculty” status only to those who possess a master’s degree in their field, this requirement is deemed impliedly written in employment contracts. The Court argued that prospective educators are presumed to know these mandated qualifications. Thus, even with three years of satisfactory service, those who do not meet these criteria cannot attain permanent status.
The Court referenced the ruling in Lacuesta v. Ateneo de Manila University, where it was stated that part-time teachers cannot acquire permanent status. In this case, Manaois, lacking the necessary master’s degree, could only be considered a part-time instructor. Therefore, SSC had no legal obligation to reappoint her after her temporary appointment lapsed. This decision underscores the importance of meeting academic qualifications for securing a permanent teaching position in private educational institutions.
FAQs
| What was the key issue in this case? | The central issue was whether St. Scholastica’s College (SSC) was justified in not renewing Jocelyn Herrera-Manaois’ contract as a full-time faculty member because she did not obtain a master’s degree. The court examined whether a master’s degree was a valid requirement for tenure. |
| What did the Supreme Court decide? | The Supreme Court ruled in favor of SSC, affirming that private educational institutions can require a master’s degree for permanent full-time faculty status. The court emphasized the institution’s right to set academic standards. |
| What is probationary employment according to the Labor Code? | Probationary employment is a trial period during which an employer assesses an employee’s competency. The employer can terminate the employment if the employee fails to meet reasonable standards made known at the time of engagement. |
| How did the SSC Faculty Manual factor into the decision? | The SSC Faculty Manual explicitly stated that a master’s degree was required for permanency. The court found that Manaois’s employment contract incorporated these rules, making her aware of the requirement. |
| Does satisfactory performance during probation guarantee permanent employment? | No, satisfactory performance alone is not sufficient. The employee must also meet all other reasonable standards set by the institution for permanent employment, such as academic qualifications. |
| What is the role of government regulations in this context? | Private educational institutions must also comply with government regulations, such as the 1992 Manual of Regulations for Private Schools. These regulations set minimum qualifications for faculty members, including the requirement of a master’s degree for tertiary-level instructors. |
| What was the basis for the Labor Arbiter’s initial decision? | The Labor Arbiter initially ruled that the requirement to finish the master’s degree was not adequately communicated to her at the start of her engagement. However, this decision was later reversed by the Court of Appeals and the Supreme Court. |
| What happens if a teacher does not meet the qualifications for full-time status? | If a teacher does not meet the qualifications for full-time status, they may be considered a part-time instructor. Part-time instructors typically do not acquire the same rights to permanent employment as full-time teachers. |
This ruling underscores the importance of aligning employment contracts and institutional policies with both the Labor Code and relevant government regulations. Educational institutions must clearly communicate academic requirements to probationary employees, and employees must strive to meet these standards to secure permanent positions. This ensures quality education and protects the rights of both the employer and the employee.
For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.
Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Jocelyn Herrera-Manaois v. St. Scholastica’s College, G.R. No. 188914, December 11, 2013
Leave a Reply