The Supreme Court ruled that while a teacher’s act of altering failing grades might be misconduct, it doesn’t automatically warrant dismissal. The key is whether the teacher acted with wrongful intent. Absent such intent and considering factors like length of service and lack of prior offenses, dismissal can be deemed illegal. This decision emphasizes that employers must consider the severity of the misconduct in relation to the penalty imposed, especially for long-term employees with clean records. The case underscores the importance of substantial due process in employment termination, requiring employers to demonstrate just cause and adherence to fair procedures.

When Good Intentions Go Wrong: Was Changing Grades Serious Misconduct?

In the case of National Labor Relations Commission v. Salgarino, a mathematics teacher, Ma. Bernadette Salgarino, was dismissed from St. Jude Catholic School for altering the grades of her students while on maternity leave. The school argued this constituted serious misconduct justifying her termination. Salgarino contended she acted out of humanitarian considerations, believing the students deserved a passing grade. The central legal question was whether her actions, though a breach of school policy, amounted to serious misconduct meriting dismissal.

The Labor Code defines serious misconduct as a just cause for termination, but the Supreme Court clarified its meaning. Misconduct is an improper or wrong conduct, a transgression of an established rule. To be considered ‘serious,’ it must be of a grave and aggravated character, not merely trivial or unimportant. Critically, it implies wrongful intent, not just an error in judgment. This distinction became the crux of the court’s decision. It’s not enough that a rule was violated; the employee’s state of mind matters.

The Court considered Salgarino’s motive. She claimed her students’ failing grades were due to a lack of instruction during her absence. Moreover, she believed that failing them would violate school regulations regarding summer class enrollment. The Court found no evidence of ulterior motive or immoral consideration. Salgarino’s actions were born from a desire to help her students, albeit misguidedly. The court noted the absence of wrongful intent. It classified her offense as simple misconduct, insufficient for dismissal. A mere mistake in judgment isn’t enough to justify termination.

Building on this principle, the Court also took into account Salgarino’s tenure and record. She had served the school for over ten years without prior disciplinary issues. Dismissal seemed a disproportionately harsh penalty for a first offense. The penalty should fit the crime, a principle deeply ingrained in labor law. The Court has consistently held that penalties must be commensurate with the offense’s gravity.

This approach contrasts with the school’s interpretation of the Manual of Regulations for Private Schools. The school cited Section 94(b), allowing termination for “negligence in keeping school or student records, or tampering with or falsification of the same.” However, the Court emphasized that “may” is permissive, not mandatory. It grants discretion but doesn’t compel termination. The school’s authority wasn’t absolute. It was subject to fairness and the employee’s constitutional right to protection. The Court also dispensed with arguments relating to breach of trust. Loss of confidence is valid ground for termination under Article 282 of the Labor Code but applies only to managerial roles and employees handling money or property – not in this case of a school teacher.

Focusing on the procedural elements of dismissal, the Court acknowledged that St. Jude Catholic School had followed the correct steps by providing notices, holding a hearing, and issuing a termination letter, thus satisfying procedural due process. However, while the procedure was right, the substance was wrong: they failed to establish a valid or just cause for her termination. Substantive due process means the dismissal must be for a legitimate reason.

Therefore, while teachers should abide by school rules when it comes to the objectivity of grading, the termination of a teacher based on alteration of grades will depend on circumstances, the presence of wrongful intent and the gravity of the act. The High Court gave equal weight to the length of service and absence of any derogatory record in invalidating the dismissal of the teacher.

FAQs

What was the key issue in this case?	The key issue was whether the teacher’s act of changing failing grades to passing grades constituted serious misconduct warranting her dismissal from employment.
Did the school follow the correct procedure for dismissal?	Yes, the Court found that the school followed the procedural requirements for dismissing an employee. However, they failed to prove just cause, meaning the dismissal lacked substantive due process.
What is the difference between serious misconduct and simple misconduct?	Serious misconduct involves wrongful intent and grave transgression of rules, while simple misconduct is a less severe violation without malicious intent. Only serious misconduct is a just cause for dismissal.
Does academic freedom give a teacher the right to change grades?	No, the Court clarified that academic freedom refers to the freedom of teachers in their research and expression. It does not extend to the discretion of arbitrarily changing grades.
What does “loss of confidence” mean in employment law?	Loss of confidence is a ground for dismissal but typically applies to employees in positions of trust, such as managers or those handling finances. It usually does not apply to regular teaching staff.
What factors did the Court consider in this case?	The Court considered the teacher’s intent, the severity of the misconduct, her length of service, and her lack of prior offenses. It weighed these factors in determining whether the dismissal was justified.
What is the meaning of the word ‘may’ in school regulations?	When regulations say someone ‘may’ be terminated for certain actions, it indicates the employer has discretion but is not obligated to terminate the employee.
What was the final decision of the Supreme Court?	The Supreme Court affirmed the Court of Appeals’ decision, ruling that the teacher was illegally dismissed. The school was ordered to reinstate her and pay backwages.

In conclusion, this case serves as a reminder that while employers have the right to enforce their policies, they must exercise that right reasonably and fairly. Dismissal is a severe penalty that should be reserved for serious offenses, particularly when dealing with long-term employees who have otherwise been competent and dedicated.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: NATIONAL LABOR RELATIONS COMMISSION v. SALGARINO, G.R. No. 164376, July 31, 2006