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	GR No. 172818 2009-03-31	SPS. ALWYN ONG LIM AND EVELYN LUKANG LIM v. LEGAZPI HOPE CHRISTIAN SCHOOL QUISUMBING, J.
In University of Sto . Tomas v. NLRC,[23] we ruled that for a private school teacher to acquire permanent status in employment, the following requisites must concur: (1) the teacher is a full-time teacher; (2) the teacher must have rendered three consecutive years of service; and (3) such service must have been satisfactory.[24]
	GR NO. 157788 2005-03-08	SAINT MARY’S UNIVERSITY v. CA QUISUMBING, J.
Section 93 of the 1992 Manual of Regulations for Private Schools, provides that full-time teachers who have satisfactorily completed their probationary period shall be considered regular or permanent.[6] Furthermore, the probationary period shall not be more than six consecutive regular semesters of satisfactory service for those in the tertiary level.[7] Thus, the following requisites must concur before a private school teacher acquires permanent status: (1) the teacher is a full-time teacher; (2) the teacher must have rendered three consecutive years of service; and (3) such service must have been satisfactory.[8]