Case Summary (G.R. No. 115795)
Petitioner
Jose S. Santos, Jr., employed as a teacher from June 1980 until his dismissal effective June 1, 1991, charged with “immorality” for engaging in an illicit relationship with a co-teacher.
Respondents
– Hagonoy Institute Inc. (private employer)
– Marta B. Zuniga (Directress)
– Elisea B. Banag (Principal)
– National Labor Relations Commission (NLRC)
Key Dates
• June 1980: Petitioner’s employment begins
• November 1990: Rumors prompt internal investigation; Mrs. Martin suspended and subsequently dismissed
• December 19, 1990: Administrative charge filed against petitioner
• June 1, 1991: Petitioner’s dismissal takes effect
• January 12, 1993: Labor Arbiter dismisses petitioner’s illegal dismissal complaint but grants financial assistance
• November 29, 1993: NLRC affirms Labor Arbiter’s decision
• March 6, 1998: Supreme Court decision
Applicable Law
• 1987 Philippine Constitution, Art. XV, Sec. 2 (protection of marriage and the family)
• Labor Code, Art. 282 (just causes for dismissal)
• DECS Manual of Regulations for Private Schools, Sec. 94(E) (disgraceful or immoral conduct as ground for termination)
• Family Code, Arts. 1, 68, 218 (marriage, spousal obligations, and special parental authority)
Facts
Petitioner and Mrs. Martin allegedly entered into a romantic relationship during school hours. Rumors circulated among faculty and staff. The Institute formed a committee, which, after two weeks of inquiry, confirmed the affair. Mrs. Martin was first dismissed for insubordination without procedural due process; petitioner was later charged administratively, given hearings, and dismissed for immorality.
Procedural History
– Mrs. Martin’s illegal dismissal complaint before NLRC succeeded on procedural grounds.
– Petitioner filed an illegal dismissal complaint with the NLRC Regional Arbitration Branch No. III.
– Labor Arbiter dismissed the complaint but awarded financial assistance.
– NLRC upheld the dismissal and assistance award.
– Petitioner’s motions for reconsideration were denied.
– Petitioner filed a certiorari petition under Rule 65.
Legal Issue
Does an extramarital affair between married teachers constitute “immorality” under Art. 282 and Sec. 94(E), justifying dismissal, and was due process afforded?
Court’s Analysis on Just Cause and Due Process
- Dismissal must be supported by a cause enumerated in Art. 282 and by procedural due process (notice and hearing).
- The Institute conducted an exhaustive administrative inquiry: committee investigation, formal charge, opportunity to present evidence, and hearing.
Definition and Standard of Immorality for Teachers
Immorality is a course of conduct that offends community morals and undermines the teacher’s role as a model. Given teachers’ special parental authority and in loco parentis status, both on- and off-duty behavior must be beyond reproach.
Evidence and Burden of Proof
The employer bore the burden of proving immoral conduct by substantial evidence. Nine witnesses—including students, a security guard, a janitor, and six co-teachers—testified to the affair. Petitioner’s unsubstantiated deni
Case Syllabus (G.R. No. 115795)
Facts
- Petitioner Jose S. Santos, Jr., a married man, was employed as a teacher by Hagonoy Institute Inc. from June 1980 until his dismissal effective June 1, 1991.
- Co-respondent Arlene T. Martin, also a married teacher at the same institution, entered into an illicit relationship with petitioner during their employment.
- Rumors of their affair circulated among faculty and school officials, prompting the private respondent to advise Martin on November 3, 1990 to take a leave of absence; she refused and continued reporting for work.
- On November 9, 1990, Martin was barred from the school premises and effectively dismissed; she subsequently filed an illegal dismissal complaint before NLRC Regional Arbitration Branch No. III, San Fernando, Pampanga.
- Hagonoy Institute formed an investigatory committee which, after two weeks, confirmed the illicit relationship; petitioner was formally charged for immorality on December 19, 1990, given opportunity to present his side, and ultimately informed in May 1991 that he would be dismissed as of June 1, 1991.
Procedural History
- Martin’s illegal dismissal case was dismissed by Labor Arbiter Ariel Santos but reversed by the NLRC on February 26, 1993 for lack of procedural due process; she was awarded back wages and separation pay.
- Petitioner filed his own illegal dismissal complaint on August 12, 1991 before the same NLRC branch.
- Labor Arbiter Quintin C. Mendoza issued a decision on January 12, 1993 dismissing petitioner’s complaint yet granting financial assistance of ₱13,750.00.
- On November 29, 1993, the NLRC dismissed petitioner’s appeal and denied his motion for reconsideration, upholding the labor arbiter’s finding of just cause.
- Petitioner then sought certiorari relief under Rule 65 of the Rules of Court; this petition was resolved by the Supreme C