Teachers Must Display Exemplary Behavior

“[T]eachers must adhere to the exacting standards of morality and decency. There is no dichotomy of morality. A teacher, both in his official and personal conduct, must display exemplary behavior. He must freely and willingly accept restrictions on his conduct that might be viewed irksome by ordinary citizens. In other words, the personal behavior of teachers, in and outside the classroom, must be beyond reproach.“

The foregoing principles were applied by the Supreme Court in the case of Santos v. Hagonoy Institute¹G.R. No. 115795, March 6, 1998, the facts of which are as follows:

Jose, a married man, was employed as a teacher by the Hagonoy Institute,
Inc. Likewise working as a teacher in the same school was Arlene, also married.

In the course of their employment, the couple fell in love. Thereafter, rumors regarding the couple’s relationship spread, especially among the faculty members and school officials.

Concerned about the rumors, Hagonoy Institute advised Arlene to take a leave of absence which she ignored, as she continued to report for work. Consequently, she was barred from reporting for work and was not allowed to enter the school premises, thereby effectively dismissing her from her employment. Meanwhile, Hagonoy Institute set up a committee to investigate the veracity of the rumors. After two weeks of inquiry, the committee rendered its report confirming the illicit relationship between Jose and Arlene. Thus, Jose was dismissed from his employment.

Unable to accept such verdict, Jose filed a complaint for illegal dismissal.

Can the relationship between Jose and Arlene be considered as immorality to constitute just cause for dismissal?

The Supreme Court ruled that the illicit relationship between Jose and Arlene
is immoral, a serious offense, and therefore, a valid cause for his dismissal.

The Court stated that teachers are important to society in that they are given substitute and special parental authority under our laws. Thus, teachers must adhere to the exacting standards of morality and decency. There is no dichotomy of morality. A teacher, both in his official and personal conduct, must display exemplary behavior. He must freely and willingly accept restrictions on his conduct that might be viewed irksome by ordinary citizens. In other words, the personal behavior of teachers, in and outside the classroom, must be beyond reproach. Consequently, when a teacher engages in extra-marital relationship, especially when the parties are both married, such behavior amounts to immorality, justifying his termination from employment.

In the present case, the Court found that the gravity and seriousness of Jose’s offense stemmed from his being a married man and at the same time a teacher. Jose served as an example to his pupils, especially during their formative years²Chiang Kai Shek School v. Court of Appeals, 172 SCRA 389 (1989) and stands in loco parentis to them.³Bagayo v. Marave, 86 SCRA 389 (1978) However, his act of having an extra-marital affair was an affront to the sanctity of marriage, which is a basic institution of society. As Jose’s extra-marital affair with Arlene was established, the Supreme Court ruled that his dismissal from employment was justified.

Further reading:

• Santos, Jr. v. National Labor Relations Commission, G.R. No. 115795, March 6, 1998.