Jan Michael G.

Limmayog
Advanced Legal Writing, LLB III-A
April 22, 2015

I. ORIGINAL:
1. INTRODUCTION: In the interest of those it has sworn to serve,
Saint Louis University as a formidable educational institution must keep
its standards at the highest bar. Failing to do such, its constituents, the
students, ultimately suffer a lapse in quality maintenance. As such, it
adopts mechanisms which are both reasonable and humane to ensure
that it lives up to its Christian spirit of service. Having found herein
petitioner Evangeline C. Cobarrubias repetitively remiss of her
performance as an educator, the respondent had every right in law and
principle to terminate her from service. None other than the highest
court agreed to such action by the respondent, which the respondent
reiterates herein, hence this appeal.

MAIN: A prestigious educational institution committed and driven

in every sense to the provision of top quality education cannot
afford any inferiority in its services.

2. CONCLUSION: The highest court of the land has spoken, and

matters settled therein must remain undisturbed.
In vain, the
petitioner has repeated history in every point, and the respondent
merely executed a device assured of it by the Supreme Courts earlier
ruling. Hence, it would be a stretch to declare the CBA void as basis
for illegal dismissal as this would denigrate from the Supreme Courts
earlier decision. Thus, it is prayed for that the Regional Arbitration
Branchs decision must be reversed and set aside.

MAIN IDEA: Jurisprudence, having become part of the law of the

land, must be followed and not contravened.
II. REWRITTEN:

1. INTRODUCTION: A prestigious educational institution committed

and driven in every sense to the provision of top quality education
cannot afford any inferiority in its services. Such is the status of Saint
Louis University of Baguio City, which has, for decades, produced
bright and highly capable graduates due to its prodigious educational
standards. Thus, in keeping with its dedication to its students, Saint
Louis University has every right pursuant to Labor Law and to a valid
Collective Bargaining Agreement to discipline, reprimand, suspend, or
even remove an errant employee. Under such cause, it was then
proper for it to have terminated the services of herein petitioner
Evangeline C. Cobarrubias who has consistently and repetitively been
remiss of her performance as an educator. None other than the
highest court agreed to such action by the respondent as was settled
in a previous case involving the same parties, which the respondent
reiterates herein, hence this appeal.
2. CONCLUSION: Jurisprudence, having become part of the law of
the land, must be followed and not contravened. It is of note that the
present case involves the same issues, parties, and subject matter,
which none other than the Supreme Court has decided upon with
finality in favor of Saint Louis University. As the rules of court and case
law would hold, issues finally settled must be laid to rest and never

Jan Michael G. Limmayog

Advanced Legal Writing, LLB III-A
April 22, 2015

disturbed. Hence, it would be contrary to labor law, jurisprudence, and

the rules of procedure for this tribunal to declare that the CBA is void.
Such declaration would contravene the recent ruling of the Supreme
Court, since Res Judicata had already set in. Thus, it is prayed for that
the Regional Arbitration Branchs decision must be reversed and set
aside.