O but to order reinstatement at this juncture would

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on
probation
as
a
general
utility
workers.
 Upon
 expiration
 of
 the
 period
 of
 6
 months,
 Dequila
 was
 informed
 that
 his
 work
 had
 proved
 unsatisfactory.
 To
 give
 him
 a
 chance
 to
 improve
 his
 performance,
 Mariwasa,
 with
 his
 written
 consent,
 extended
 his
 probation
 period
 for
 another
3
months.
Dequila
was
dismissed.
 o The
 extension
 of
 Dequila’s
 probation
 was
 an
 act
 of
 liberality
 on
the
part
of
his
employer
affording
him
a
second
chance
to
 make
 good
 after
 having
 initially
 failed
 to
 prove
 his
 worth
 as
 an
 employee.
 By
 voluntarily
 agreeing
 to
 an
 extension
 of
 the
 probationary
 period,
 Dequila
 in
 effect
 waived
 any
 benefit
 attaching
 to
 the
 completion
 of
 said
 period
 if
 he
 still
 failed
 to
 make
the
grade
during
the
period
of
extension.
Nothing
in
the
 law
prohibits
such
a
waiver.
 Last
day
of
probation
 • SC
has
used
different
computation
methods
 o A
probation
of
6
months
ends
on
the
same
date
it
started
6
 months
before
 CALS
Poultry
v.
ROCO
 Computation
of
the
6‐month
probationary
 period
 is
 reckoned
 from
 the
 date
 of
 appointment
up
to
the
same
calendar
date
 of
the
6th
month
following
 o It
ends
180
days
from
the
starting
date
 Alcira
v.
NLRC
and
Middleby
 • Mitsubishi
Motors
v.
Chrysler
 o The
 probationary
 period
 of
 6
 months
 means
 180
 days
 in
 conformity
with
Article
13
of
the
Civil
Code.
Hence
the
formula
 for
6
months
probation
is
30
days
times
6
months
equals
180
 days.
 o (Latest
of
all
the
three
cases)
 Probation
of
teachers
 • Legal
 requisites
 for
 acquisition
 by
 a
 teacher
 of
 permanent
 employment,
or
security
of
tenure
–
 o The
teacher
is
a
full‐time
teacher
 o The
 teacher
 must
 have
 rendered
 3
 consecutive
 years
 of
 service
 o Such
service
must
have
been
satisfactory
 • Reversion
from
full­time
to
part­time
teacher
 o Bongar
v.
NLRC
 Bongar
was
employed
as
an
instructor
by
AMA.
His
 contract
was
renewed
several
times.
But
then
AMA
 decided
 not
 to
 renew
 the
 contract.
 Having
 served
 more
 than
 3
 years,
 Bongar
 claims
 that
 he
 has
 acquired
the
status
of
a
permanent
employee.
 36
 It
 must
 be
 noted
 that
 the
 principal
 cause
 of
 petitioner’s
 dismissal
 was
 the
 alleged
 expiration
 of
 his
 teaching
 contract.
 This
 contention
 is
 negated
 by
 the
 fact
 that
 petitioner
 had
 rendered
 service
 for
 nearly
4
years....
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