Case Digest (G.R. No. 229603) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Evelyn Chua-Qua v. Hon. Jacobo C. Clave and Tay Tung High School, Inc. (G.R. No. L-49549, August 30, 1990), petitioner Evelyn Chua-Qua had taught at Tay Tung High School in Bacolod City since 1963. In 1975 she provided remedial instruction to Bobby Qua, a Grade VI pupil fourteen years her junior. Their court marriage was solemnized on December 24, 1975 in Iloilo City with the consent of Qua’s mother and ratified by a church wedding on January 10, 1976 in Bacolod City. On February 4, 1976, the school applied to the Department of Labor for a clearance to terminate petitioner’s employment “for abusive and unethical conduct unbecoming of a dignified school teacher,” alleging that her relationship with the minor pupil was inimical to the school’s moral values. Petitioner was suspended without pay on March 12, 1976. Executive Labor Arbiter Aguirre, Jr. granted the clearance on September 17, 1976 without a formal hearing, relying on uncontroverted affidavits suggesting an amorous li Case Digest (G.R. No. 229603) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and relationship
- Evelyn Chua-Qua (petitioner) was employed as a classroom teacher at Tay Tung High School, Inc. in Bacolod City since 1963 and served as class adviser of Grade VI in 1975–1976.
- Bobby Qua, a Grade VI pupil 14 years younger than petitioner, received remedial instruction from her after school hours, during which they developed an amorous relationship.
- Marriage and administrative proceedings
- On December 24, 1975, petitioner (age 30) and Bobby Qua (age 16, with parental consent) contracted a civil marriage in Iloilo City; their union was solemnized in church on January 10, 1976, in Bacolod City.
- On February 4, 1976, the school filed with the Department of Labor an application for clearance to terminate petitioner’s employment for “abusive and unethical conduct unbecoming of a dignified school teacher.” Petitioner was suspended without pay on March 12, 1976.
- Executive Labor Arbiter Aguirre, Jr., without a formal hearing, admitted affidavits alleging petitioner lured her student into an amorous relationship and granted the clearance terminating her services on September 17, 1976.
- Petitioner appealed to the NLRC (October 7, 1976), claiming denial of due process and arguing there was nothing immoral in a lawful marriage with her student.
- On December 27, 1976, the NLRC unanimously reversed the Arbiter, finding no evidence of immoral or scandalous acts and ordering reinstatement with backwages.
- The school appealed to the Minister of Labor, which on March 30, 1977, reversed the NLRC but granted petitioner six months’ salary as financial assistance.
- Petitioner elevated the case to the Office of the President; on September 1, 1978, Presidential Executive Assistant Clave reversed the Minister’s ruling and ordered full reinstatement with backwages.
- Following a motion for reconsideration by the school, public respondent on December 6, 1978, modified his decision, allowing termination of petitioner’s services but awarding her six months’ separation pay.
- Petitioner then filed this petition for certiorari before the Supreme Court to annul the December 6, 1978 resolution.
Issues:
- Whether petitioner’s dismissal, predicated on her marriage to her pupil, was illegal.
- Whether petitioner’s right to due process was violated by the admission of hearsay affidavits without opportunity to confront and cross-examine the affiants.
- Whether there was sufficient proof of serious misconduct, immorality, or breach of trust under Article 283 (now 282) of the Labor Code to justify termination.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)