FACTS:
The petitioner, a classroom teacher, had been employed by Tay Tung High School, Inc. since 1963. In 1976, the petitioner, who was thirty years old, married her student, Bobby Qua, who was fourteen years younger. The marriage was ratified in both a civil and church ceremony. Following the marriage, the private respondent filed an application to terminate the petitioner's employment, alleging abusive and unethical conduct. They claimed that the petitioner and Bobby Qua had an amorous relationship and stayed alone together in the classroom after school hours. The executive labor arbiter granted the clearance to terminate the petitioner's employment based on the affidavits submitted by the private respondent, without a formal hearing. The petitioner, however, claimed she did not receive a copy of the affidavits and appealed to the National Labor Relations Commission for denial of due process. The Commission reversed the labor arbiter's decision and ordered the petitioner's reinstatement. The case was elevated to the Minister of Labor, who reversed the Commission's decision but awarded the petitioner six months' salary as financial assistance. The petitioner appealed to the Office of the President, which initially ordered her reinstatement with full back wages but eventually modified its decision, allowing the termination of the petitioner's services but granting her separation pay equivalent to six months' salary. Dissatisfied, the petitioner filed a petition for certiorari, seeking the reversal of the reconsidered decision.
ISSUES:
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Whether the dismissal of petitioner's employment on the ground of her marriage to her pupil is illegal.
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Whether petitioner's right to due process was violated when hearsay affidavits were admitted and considered as evidence without affording her the right to confront and cross-examine the affiants.
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Whether there is sufficient evidence to prove that petitioner committed serious misconduct or breached the trust reposed on her, justifying the termination of her employment.
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Whether there is substantial evidence to support the alleged immoral acts committed by the appellant and her student.
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Whether the appellant violated the Code of Ethics governing school teachers.
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Whether the dismissal of the appellant is justified.
RULING:
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The dismissal of petitioner's employment was not based on her marriage with her pupil, but on her actuations and behavior that had spawned ugly rumors and cast serious doubts on her integrity. The school authorities had the right to uphold the judgment and action of the school authorities in terminating her services for the sake of the well-being and reputation of the school community.
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Petitioner's right to due process was not violated. She was afforded an opportunity to present her side, and the procedure by which issues were resolved based on position papers, affidavits, and other documentary evidence is recognized as not violative of due process. Petitioner could have insisted on a hearing to confront and cross-examine the affiants but chose not to.
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The determination of the legality of the dismissal is based on whether there is substantial evidence to prove that the antecedent facts leading to the marriage between petitioner and her student constitute immorality and/or grave misconduct. The Court ruled that the issue is a factual question, which is better left to the trier of facts. Public respondent, in this case, acted with grave abuse of discretion and his decision is nullified.
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There is no sufficient evidence to prove that immoral acts were committed by the appellant and her student. The affidavits relied upon by the appellee were prepared after the disciplinary action was sought, and there was a significant delay in seeking the action. The dismissal based on alleged immoral acts is open to question.
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The appellant did not take advantage of her position to court her student. The fact that the two eventually fell in love does not necessarily equate to immorality. The deviation of their circumstances from the usual societal pattern is not a defiance of contemporary social mores.
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The dismissal of the appellant is unwarranted and illegal. The burden of proving just and valid cause for dismissing an employee rests on the employer, and in this case, the charge against the appellant was not substantiated. However, due to the severe strain in the relationship between the appellant and the private respondent, reinstatement is not ordered. The appellant is entitled to backwages equivalent to three years and separation pay.
PRINCIPLES:
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The dismissal of an employee based on actuations and behavior that cast serious doubts on integrity and create a negative atmosphere in a school community can be upheld in order to prioritize the interests of the children and maintain a healthy school environment.
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The procedure of resolving issues based on position papers, affidavits, and other documentary evidence does not violate the right to due process as long as the parties are given the opportunity to present their sides.
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The determination of whether an act constitutes immorality depends on the particular circumstances of each case, to be evaluated in the light of prevailing norms of conduct and the applicable law.
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The findings of fact must be supported by substantial evidence for the court to be bound by them.
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The burden of proving just and valid cause for dismissing an employee rests on the employer.
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The mere fact that two individuals fall in love, despite age and academic level differences, does not automatically equate to immorality.
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The deviation of the circumstances of marriage from the usual societal pattern does not necessarily defy contemporary social mores.