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RENE VENTENILLA PUSE v. LIGAYA DELOS SANTOS-PUSE

FACTS:

The petitioner, Rene V. Puse, is a registered Professional Teacher stationed at S. Aguirre Elementary School, while the respondent, Ligaya Delos Santos-Puse, is a Barangay Rural Health Midwife. The petitioner was found to be married to another woman before marrying the respondent. The respondent filed a criminal case against the petitioner for "Bigamy" and "Abandonment." The respondent also filed a complaint with the Professional Regulation Commission (PRC) seeking assistance. The petitioner denied the charges and argued that the respondent should be held equally guilty. The PRC found a prima facie case against the petitioner and revoked his license as a Professional Teacher.

The petitioner, a public school teacher, was found guilty of immorality and dishonorable conduct by the Board of Professional Teachers. The petitioner's motion for reconsideration was denied, and he appealed to the Court of Appeals, which upheld the Board's findings. Dissatisfied, the petitioner filed a petition for review before the Supreme Court. The petitioner argued that the Board did not have jurisdiction over the complaint and that he was denied due process. The Supreme Court disagreed and stated that the Board, the Department of Education, and the Civil Service Commission have concurrent jurisdiction over administrative cases involving immoral, unprofessional, or dishonorable conduct.

There are three agencies that have jurisdiction over administrative complaints against teachers. The PRC has jurisdiction over complaints filed under the Philippine Teachers Professionalization Act of 1994. The DepEd has jurisdiction over complaints against public school teachers filed under the Magna Carta for Public School Teachers. The CSC has jurisdiction over administrative disciplinary cases involving government employees. When there is concurrent jurisdiction, the first agency to take cognizance of the complaint shall have exclusive jurisdiction.

ISSUES:

  1. Whether the Board of Professional Teachers had jurisdiction over the case

  2. Whether petitioner was denied administrative due process

  3. Did the petitioner receive due process in the administrative proceedings?

  4. Was there substantial evidence to prove that the petitioner was guilty of immoral and dishonorable conduct?

  5. Whether or not the teacher's extra-marital relationship constitutes immorality.

  6. Whether or not the teacher's conduct justifies termination from employment.

  7. Whether the petitioner's act of entering into a second marriage constitutes grossly immoral conduct.

  8. Whether the revocation of the petitioner's license as a penalty for his immoral conduct is appropriate.

RULING:

  1. The Board of Professional Teachers had jurisdiction over the case.

  2. Petitioner was not denied administrative due process.

  3. The petitioner was afforded due process in the administrative proceedings. Although he claims to have been unaware of the retraction of the complaint against him, he still had the opportunity to question it in his motion for reconsideration.

  4. There was substantial evidence to prove that the petitioner was guilty of immoral and dishonorable conduct. The Board and the Court of Appeals found that the petitioner's belief that his first wife was already dead was untenable, as she regularly sent financial support to her family and visited them in the Philippines at least once a year.

  5. Yes, the teacher's extra-marital relationship constitutes immorality. The Code of Ethics of Professional Teachers states that teachers must adhere to a standard of personal conduct that prohibits behavior creating a suspicion of immorality due to the harmful impression it might have on students. Engaging in an extra-marital relationship, especially when both parties are married, is considered immoral.

  6. Yes, the teacher's conduct justifies termination from employment. Teachers must conform to the standards, principles, and values laid down in the Code of Ethics of Professional Teachers. Deviation from these standards renders a teacher unfit to continue practicing their profession. The teacher's failure to follow the tenets of morality, specifically by contracting a bigamous marriage and keeping it secret from his second wife, damaged the teaching profession and made him unfit to be a model worthy of emulation.

  7. The petitioner's act of entering into a second marriage constitutes grossly immoral conduct, as it demonstrates a lack of moral character and respect for the sanctity of marriage.

  8. The penalty of revoking the petitioner's license was upheld as appropriate, considering the gravity of his offense and the discretion granted to the Board of Professional Teachers to impose penalties for immoral conduct.

PRINCIPLES:

  • The Civil Service Commission (CSC) has jurisdiction to supervise and discipline all government employees, including those employed in government-owned or controlled corporations with original charters. Complaints for violations of civil service rules and regulations may be filed with the CSC. However, where concurrent jurisdiction exists in several tribunals, the body or agency that first takes cognizance of the complaint shall exercise jurisdiction to the exclusion of the others.

  • Technical rules of procedure are liberally applied in administrative cases. Administrative due process cannot be fully equated with due process in its strict judicial sense. The essence of administrative due process is an opportunity to explain one's side or seek reconsideration of the action or ruling complained of.

  • In establishing bias or partiality, convincing extrinsic evidence is required. The presumption of regularity in the performance of official duty prevails in the absence of such evidence.

  • Presumption of regularity in the performance of official duty prevails when there is no evidence to establish bias.

  • Failure to adduce evidence to prove bias and violation of due process results in the presumption of regularity.

  • Technical rules of procedure and evidence are not strictly applied in administrative proceedings.

  • Technical errors in the admission of evidence that do not prejudice the substantive rights of the parties will not vitiate the proceedings.

  • Licensed professionals are required to adhere to and observe the ethical and moral principles, standards, and values set forth in their respective code of ethics.

  • Immorality is determined by considering the circumstances of each particular case in light of prevailing norms of conduct and applicable laws.

  • Teachers are expected to display exemplary behavior in both their official and personal conduct, adhering to a high standard of morality and decency.

  • Teachers must abide by a standard of personal conduct that not only prohibits immoral acts but also behavior creating suspicion of immorality.

  • The Code of Ethics of Professional Teachers contains ethical and moral principles that teachers must strictly adhere to, including standards of dignity, honor, and refraining from illicit relations.

  • Deviation from the prescribed standards, principles, and values in the Code makes a teacher unfit to continue practicing their profession, and any damage caused to the teaching profession due to immoral conduct justifies termination from employment.

  • A husband has duties to his wife, including living with her, showing mutual love and respect, providing support, and remaining faithful to her until death.

  • The act of entering into a second marriage while the first one is still subsisting constitutes grossly immoral conduct, as it disregards the sanctity and respectability of marriage.

  • The penalty imposed for grossly immoral conduct by the Board of Professional Teachers is at its discretion, guided by the provisions of Rep. Act No. 7836, and may include revocation of the teacher's license.