Cadiz was the Human Resource Officer of Brent Hospital and Colleges, Inc.
Brent is an institution of the Episcopal Church in the Philippines.
She was suspended from employment in 2006 on the grounds of Unprofessionalism and
Unethical Behavior resulting to Unwed Pregnancy.
The suspension will be lifted upon her marriage to her boyfriend.
The Labor Tribunal ruled that there was just cause for her dismissal. She was not entitled to
reinstatement until the marriage, as well as to backwages and vacation/sick leave pay. She
could only receive her 13th month pay (April 12, 2007).
Cadiz appealed to the National Labor Relations Commission (NLRC), which affirmed the LA
decision ( December 10, 2007).
The Court of Appeals also dismissed her petition due to technical defects in the petition (July
22, 2008).
Issues:
1. Whether Cadizs premarital relations with her boyfriend and the resulting pregnancy
out of wedlock constitute immorality.
No. The foregoing circumstances do not readily equate to disgraceful and immoral
conduct. Brents Policy Manual and Employees Manual of Policies do not define what
constitutes immorality. As laid down in the case of Leus v. St. Scholasticas College
Westgrove, a disgraceful conduct should be detrimental to conditions upon which
depend the existence and progress of human society. The fact that a particular act
does not conform to the traditional moral views of a certain sectarian institution is
not sufficient reason to qualify such act as immoral unless it, likewise, does not
conform to public and secular standards. More importantly, there must be substantial
evidence to establish that premarital sexual relations and pregnancy out of wedlock
is considered disgraceful or immoral. The fact that Brent is a sectarian institution
does not automatically subject Cadiz to its religious standard of morality.
2. Whether marriage can be a condition for reinstatement.
No. It is true that the doctrine of management prerogative gives an employer the right
to regulate, according to his own discretion and judgment, all aspects of employment.
However, there are statutory laws that protect labor and promote equal opportunity
in employment which may contravene this prerogative. In consideration of Art. 136
of the Labor Code and RA No. 9710, Brents condition is coercive, oppressive, and
discriminatory. Brent failed to prove that the said marriage is an employment
qualification that is reasonably related to the essential operation of the job involved
and that the absence of said condition will result to Cadiz inability to properly
perform the duties of the job. The imposition of such condition deprives her of her
freedom to choose her status.