GR 164376; (July, 2006) (Digest)
G.R. No. 164376 ; July 31, 2006
NATIONAL LABOR RELATIONS COMMISSION, ET AL., petitioners, vs. MA. BERNADETTE S. SALGARINO, respondent.
FACTS
Respondent Ma. Bernadette Salgarino was a Mathematics teacher at St. Jude Catholic School. In February 1999, she went on maternity leave. During her leave, substitute teachers administered the periodical test and computed the preliminary grades, which showed some failing students. Respondent, without prior school permission, requested the delivery of the grading sheets to her house. She then encircled the failing grades and wrote a passing grade of 75% beside them, justifying her act based on her assessment of the students’ performance in projects and make-up tests she had conducted, and to prevent a potential violation of school regulations on summer classes.
Upon discovering the alterations, the school conducted an investigation. The investigating panel found that respondent tampered with official student records while on leave, constituting negligence and falsification under the Manual of Regulations for Private Schools. Consequently, her employment was terminated. Respondent filed a complaint for illegal dismissal.
ISSUE
Whether the respondent was illegally dismissed.
RULING
No, the dismissal was valid. The Supreme Court reversed the Court of Appeals and upheld the NLRC’s finding of a just cause for termination. The legal logic centers on the employer’s right to dismiss an employee for just cause under Article 282 of the Labor Code, which includes serious misconduct and willful breach of trust.
The Court found that respondent’s act of unilaterally altering the grades on official school records constituted tampering and falsification, a specific ground for termination under the Manual of Regulations for Private Schools. Her defense of academic freedom or humanitarian reasons was unavailing. Academic freedom does not grant a teacher the license to arbitrarily change final grades computed and recorded by substitute teachers during her authorized absence, especially without administrative consent. Her actions demonstrated a willful disregard of established school policies and procedures for grading, which are designed to maintain academic integrity. This breach eroded the trust essential to the employer-employee relationship, particularly for a teacher entrusted with maintaining accurate scholastic records. The investigation conducted by the school was sufficient and afforded her due process. Thus, her dismissal was for a just and authorized cause.