Happy Valentines! Church historians associate the celebration of Valentines Day with St. Valentine. Just like Christmas, many people now ignore the religious significance of St. Valentines Day but anticipate and join in the celebrations. Our laws are meant to regulate our conduct and behaviour towards each other but we cannot expect it to interfere with the most less understood emotion- LOVE. We know too well that it cannot be regulated by any law in the first place. It has even launched a thousand ships, caused the failure of defensive structures of great countries, brought down great dynasties… It cannot be regulated, it cannot be contained. So whenever the subject about love surfaces in discussions in law classes, it naturally attracts attention. The Chua-Qua Vs Clave is a landmark case, a testament to the power of love that even the seemingly stiff justices of the Supreme Court have no power to resist.
Chua-Qua vs. Clave
Bobby Qua was 16 years old while Evelyn Chua was 30 when they got married. Bobby was Evelyn’s student. A year after their marriage, Evelyn was dismissed from her employment as a teacher after the school obtained a clearance from the National Labor Relations Commission. The school justified its action thus: “For abusive and unethical conduct unbecoming of a dignified school teacher and that her continued employment is inimical to the best interest, and would downgrade the high moral values, of the school.” (G.R. No. L-49549, 30 August 1990). The case went all the way to the Office of the President and the ruling of Executive Assistance Jacobo Clave stated that: “this Office deemed it wise to uphold the judgment and action of the school authorities in terminating the services of a teacher whose actuations and behavior, in the belief of the school authorities, had spawned ugly rumors that had cast serious doubts on her integrity, a situation which was considered by them as not healthy for a school campus, believing that a school teacher should at all times act with utmost circumspection and conduct herself beyond reproach and above suspicion”.
The Court’s Decision
When the case eventually reached the Supreme Court, it sided with Evelyn. The school was wrong in terminating her employment based on moral grounds. The Supreme Court found that the ultimate reason why Evelyn was removed was her marriage to her student who was 14 years her junior. The school argued that Evelyn abused her authority as a teacher and this is a violation of the Code of Ethics of the school which justifies her dismissal. The Supreme Court did not agree. There was no evidence that Evelyn and Bobby engaged in immoral or scandalous acts and the real reason for the termination of Evelyn’s employment was her marriage to her student Bobby. Said the SC: “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…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.” (emphasis supplied). The High Tribunal certainly did not consider the marriage between a teacher and her student as an immoral act which might constitute as a valid ground for dismissal. Some might be surprised with the huge age difference between the teacher and student but this cannot be a sufficient ground for the violation of the Constitutionally guaranteed security of tenure.