- Capin Cadiz v. Brent Hospital and Colleges, G.R. No.

187417, February 24, 2016

FACTS:

Cadiz worked as an HR officer at Brent Hospital. She was engaged in a premarital

relationship with her boyfriend during her employment in the said hospital and later on
became pregnant out of wedlock. Brent fired her on the ground that her impregnation was
immoral and against Brent’s Policy Manual. Brent also said that as an HR officer, she
should be an epitome of proper conduct. Cadiz filed before Labor Tribunals complaining
about Brent’s Unfair Labor Practice, Constructive Dismissal, Non-payment of Wages,
and Damages with a prayer for reinstatement. LA dismissed the case ruling that the
action of Cadiz was indeed immoral and against the policies of her employer. The
petitioner filed the case to CA but it was dismissed because of technical deficiencies.
Hence the petition to SC.

Issues

Whether or not Cadiz’s impregnation out of wedlock is immoral.

Whether or not the marriage should be used as a condition for reinstatement.

Ruling

SC granted the petition. SC emphasized that the standard of morality should be public
and secular, not religious. The conduct, to be immoral. Should be detrimental to
conditions upon which depends on the existence and progress of human society (Leus vs.
St. Scholastica). Cited in Leus, for a conduct to be disgraceful, there must be a two-step
process: 1) a consideration of the totality of the circumstance and 2) the assessment of the
said circumstance. The totality of the circumstance doesn’t justify the alleged immoral
conduct because both Cadiz and her boyfriends were single and had no legal impediment
to marry when she got pregnant. Moreover, using marriage as a condition for Cadiz’s
reinstatement is not valid because Brent’s assertion of the doctrine of management
prerogative is violative of the constitutional rights of an employee to equal opportunity in
employment and Article 35 of The Labor Code stating that it shall be unlawful to use
marriage as a condition of employment. Therefore, Cadiz should be reinstated regardless
of the marriage.