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Is marriage of teacher and student a basis of dismissal for immorality?

Marriage is a special contract of permanent union between a man and a woman for the establishment of conjugal and family life. It is the foundation of the family and an inviolable social institution whose nature, consequences and incidents are governed by law and not subject to stipulation [Article 1, Family Code].The reason for marriage is nothing but love. It is the foundation of every marriage. Its purpose is not only for procreation [to bear children and have a family], but also for marital union and to have a perpetual companion.

The Supreme Court had occasion to rule in the 1997 Figueroa v. Barranco, case [G.R. 97369, 31 July 1997] that “we cannot castigate a man for seeking out the partner of his dreams, for marriage is a sacred and perpetual bond which should be entered into because of love, not for any other reason.

Love knows no boundaries. Love has been used as a reason for many things and sometimes as a defense. There was a 1990 case decided by the Supreme Court involving a teacher and a student relationship, who got married but was condemned by the school and used it as a ground for termination of employment. This is the case of Chua-Qua v. Clave, G.R. No. 49549, 30 August 1990.

Teacher Evelyn was a class adviser of sixth grade students in a private institution that extends remedial instructions to students as part of a school policy. Student Bobby was a recipient of that program.

In the course thereof, they fell in love and later got married. The teacher and student were 30 and 16 years old, respectively. The school terminated the teacher on ground of immorality and abusive and unethical conduct unbecoming of a dignified teacher. She allegedly defied standards of decency and took advantage of her position as teacher and lured a grade 6 boy into an amorous relation.

The Labor Arbiter ruled that while no direct proofs have been presented to show that immoral acts were committed, it is but enough for a sane mind to imagine and conclude what transpired and took place. The teacher appealed, arguing that there was nothing immoral, abusive and unethical for a school teacher to marry her student.

The National Labor Relations Commission reinstated the teacher and ordered the school to pay her backwages as there was no eyewitnesses to immoral or scandalous acts. The school appealed to the Department of Labor. It reversed the NLRC. The teacher appealed to the Office of the President. It initially reversed the DOLE decision, but later on turned over its first decision on the ground that it is not healthy for a school campus if a teacher will not conduct herself beyond reproach and above suspicion. The case reached our Supreme Court.

On the issue of dismissal of the teacher, the school argued that the teacher has moral ascendancy over the student, which she must not abuse or take advantage, otherwise the Code of Ethics for teachers is violated.

On the other hand, the teacher argued that there was no basis to terminate her services as there is nothing wrong with a teacher falling in love with her pupil and later in contracting a lawful marriage with him.

The Supreme Court ruled that to constitute immorality, the circumstances of each particular case must be holistically considered and evaluated in the light of prevailing norms of conduct and the applicable law. With the finding that there is no substantial evidence of the imputed immoral acts, it follows that the alleged violation of the Code of Ethics governing school teachers would have no basis.

The school failed to show that the teacher took advantage of her position to court her student. If the two eventually fell in love, despite the disparity in their ages and academic levels, this only lends substance to the truism that the heart has reasons of its own which reason does not know.

But, definitely, yielding to this gentle and universal emotion is not to be so casually equated with immorality. The marriage cannot be considered as a defiance of social mores.

In labor cases, the burden of proving just and valid cause for dismissing an employee rests on the employer and his failure to do so would result in a finding that the dismissal is unjustified. Fighting for the one you love pays in the end since the dismissal of the teacher was declared illegal and thus, she was awarded full backwages and separation pay.

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