Maribeth I. Espiritu v. Mahatma · G.R. 209454

Petitioner: Maribeth I. Espiritu
Respondent: Mahatma Gandhi International School
Citation: G.R. No. 209454
Court: Supreme Court
Division: Third Division
Ponente: Jr., J.
Decided: July 9, 2014

Summary

This Supreme Court case resolved a labor dispute involving salary interpretation and illegal dismissal claims. Teacher Maribeth Espiritu's employment contract contained ambiguous salary terms stating both 'Thirty Thousand Pesos' in words and 'Php20,000' in numbers. After receiving disciplinary letters, she was allegedly forced to resign and filed illegal dismissal complaint with salary differential claims. The Labor Arbiter and NLRC found no illegal dismissal but NLRC awarded salary differential for 8 months. The Court of Appeals affirmed, applying contract interpretation rules favoring the laborer. The Supreme Court ultimately granted Espiritu's petition, confirming her monthly salary as Php30,000 and ordering payment of differentials from employment start until resolution date, plus correct future salary payments. The case establishes important precedent on interpreting ambiguous employment contract terms and applying Civil Code Article 1702's pro-laborer construction rule.

Statutes applied

Civil Code, Art. 1702

Related cases

Other Philippine cases on the same provisions and issues.

Philippine National Construction Corporation v. The Honorable National Labor Relations Commission G.R. No. 101535
Bank of the Philippine Islands v. Bank of the Philippine Islands Employees Union-Metro Manila G.R. No. 175678
Magis Young Achievers' Learning Center v. Adelaida P. Manalo G.R. No. 178835
Baron Express v. Roberto F. Umanito G.R. No. 156969

By the Intellegal Editorial Board · July 9, 2014

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