Batocabe Law

Evelyn Chua was a teacher at Tay Tung High School in Bacolod City. Among her students was Bobby Qua, a sixth grader. Because the school provided remedial instruction to students who needed additional assistance, Evelyn spent extra time teaching Bobby after regular classes. Over time, the two developed feelings for one another. Eventually, they fell in love.

On December 24, 1975, they got married. The marriage was perfectly legal. Evelyn was thirty years old. Bobby was sixteen. His mother consented to the marriage, and the couple later celebrated a church wedding.

The school was not pleased.

Shortly after the wedding, Tay Tung High School sought permission to dismiss Evelyn from her employment. According to the school, she had engaged in abusive, unethical, and immoral conduct unbecoming of a teacher. The school alleged that before the marriage, Evelyn and Bobby had spent time alone together inside classrooms after school hours and that an improper relationship had existed between them.

Several affidavits were submitted. Witnesses claimed to have seen Evelyn and Bobby together inside classrooms after classes. However, none of the witnesses claimed to have actually seen any immoral act.

Despite the absence of direct evidence, the Labor Arbiter granted the school’s application to terminate Evelyn’s employment. The Arbiter reasoned that even if no one witnessed any improper conduct, a reasonable person could imagine what must have happened between the two.

The National Labor Relations Commission disagreed. It found that the affidavits merely showed that Evelyn and Bobby had been seen talking together after classes. Nothing in the affidavits established any immoral or scandalous behavior. The NLRC therefore ordered Evelyn’s reinstatement.

After a series of appeals and reversals, the case eventually reached the Supreme Court. Was the school justified in dismissing Evelyn?

No. The Supreme Court emphasized that the burden of proving a valid ground for dismissal rests upon the employer.

In this case, the school failed to present substantial evidence that Evelyn committed any immoral act. The affidavits relied upon by the school merely described instances where Evelyn and Bobby were seen together in a classroom after school hours. None of the witnesses claimed to have observed any improper conduct.

The Court was particularly critical of the reasoning that because Evelyn eventually married Bobby, one could simply infer that immoral acts must have occurred beforehand.

According to the Court, suspicion is not evidence.

The fact that two people later marry does not automatically prove that they previously engaged in misconduct. The Court refused to sustain a dismissal based on speculation, conjecture, or assumptions unsupported by proof.

The school also argued that Evelyn violated ethical standards expected of teachers. The Court rejected this argument as well.

There was no evidence that Evelyn used her position as a teacher to court Bobby. If the two eventually fell in love despite their age difference and differing academic status, that alone did not establish immorality. As the Court memorably observed, the heart has reasons of its own which reason does not know.

The Court further noted that while schools have a legitimate interest in promoting moral values, that interest cannot be used to defeat an employee’s constitutional right to security of tenure. Absent substantial evidence of wrongdoing, dismissal cannot be justified merely because an employer disapproves of an employee’s personal relationship.

Accordingly, the Supreme Court declared Evelyn’s dismissal illegal. However, recognizing that the relationship between the parties had become severely strained, the Court declined to order reinstatement. Instead, it awarded Evelyn backwages and separation pay.

Chua-Qua v. Tay Tung High School. G.R. No. 49549 August 30, 1990.