Chua-Qua vs. Clave: The heart has reasons of its own according to SC

Chua-Qua vs. Clave: The Heart Has Reasons of its Own According to SC Ruling

There are stories of romance that are inappropriate for some. But true love defies odds and overcomes hurdles. It even inspired the Supreme Court to arrive at a ruling that tugs at our heartstrings.

Years before the ratification of the 1987 Family Code of the Philippines, the old civil code extended marital rights to individuals under the age of 18 as long as there were proper consent from the parents. Interesting enough, there was this related love-story-turned-courtroom-drama that occurred during the 1970s.

Evelyn Chua and Bobby Qua

Our story began at Tay Tung High School in Bacolod City where 30-year-old Evelyn Chua had built her teaching career for the last 12 years. For the academic year 1975-1976, she handled a class of 6th grader. This was when she met 16-year-old Bobby Qua—one of her students.

A school policy also obliged teachers to extend remedial instructions to students who needed further academic assistance. Evelyn tutored Bobby nonetheless. Every after class, the two would stay in the classroom to cover lessons and other academic subjects. Over the course of their one-on-one tutorial sessions, the apparent student-teacher relationship moved up another notch. The teacher, Evelyn Chua, and the student, Bobby Qua, found themselves in love with one another.

On 24 December 1975, Evelyn and Bobby exchanged marital vows and tied the knot in a civil ceremony. Because Bobby was only 16 that time, he needed consent from his parents. On 19 January 1976, the couple observed the sacrament of holy matrimony in a ceremony officiated by a Catholic priest.

Struggles of the Newlyweds

There was no immediate happy ending for the newly weds. The marriage of a 30-year-old teacher to a 16-year-old student drew flacks from and enraged the administrators of Tay Tung High School

Tay Tung High School filed a clearance to terminate Evelyn before the sub-regional office of the Department of Labor on the grounds of “abusive and unethical conduct unbecoming of a dignified school teacher.”

The school further argued, “Her continued employment is inimical to the best interest, and would downgrade the high moral values of the school.” In other words, the school considered her a licensed professional with loose morals.

Executive Labor Arbiter Jose Y. Aguirre, Jr. of the National Labor Relations Commission, Bacolod City, required Evelyn and the school to submit position papers and evidences as affidavits.

In its affidavit, the school accused Evelyn of defying the standards of decency by recklessly taking advantage of her position as a teacher. She was accused of luring a 6th-grader under her advisory who was also 15 years her junior into an amorous relationship. The school also mentioned that the lengthy after-class tutorial was an indicator of immoral acts transpiring while in the performance of professional duty.

The Labor Arbiter decided in favor of the school saying, “While no direct evidences have been introduced to show that immoral acts were committed during these times, it is however enough for a sane and credible mind to imagine and conclude what transpired and took place during these times.” In other words, the Arbiter argued that although there was no substantial evidence, the mere fact that Evelyn pursued a relationship with Bobby was a proof that such immoral acts had transpired inside the school premises.

Evelyn lost her job. But she fought back and appealed to the National Labor Relations Commission. The denial of due process was central to her contention. She also argued that being in love with and wed-locked to her student did not make her less of a dignified teacher. The commission subsequently reversed the earlier decision to favor Evelyn on December 1976.

Pursuing the Legal Battle

Tay Tung High School refused to accept defeat however. An appeal filed with the Minister of Labor on 30 March 1977 resulted in a decision that favored the school. The Minister justified the termination of Evelyn but required the school to provide her with payouts worth her entire six-month salary.

Evelyn elevated the case to the Office of the President on 20 May 1977. Then Presidential Executive Assistant Jacobo C. Clave initially ordered the school to reinstate Evelyn.

Clave had a change of heart though. He based his new decision on the idea that the ongoing rumors about Evelyn were creating an unhealthy environment. He further noted that a school community has a delicate responsibility of nurturing children. Clave also argued that a teacher should always act beyond reproach and above suspicion.

But love was persistent. The case went all the way up to the Supreme Court. In a decision dated on 30 August 1990, the court favored the plight of Evelyn. The court also awarded her with three years back wages and a separation pay.

Then Associate Justice Florenz D. Regalado considered it unlawful to terminated Evelyn based on unproven claims of immoral conduct. In addition, he highlighted the fact that school policies should not be at odds with security of tenure. The judge also mentioned that the marriage of Evelyn to Bobby could not be taken as a proof that immoral conduct had taken place inside the school premises.

With regard to the claim that Evelyn used her authority to malign a child, Justice Regalado said, while borrowing some words from Blaise Pascal: “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. But, definitely, yielding to this gentle and universal emotion is not to be so casually equated with immorality. The deviation of the circumstances of their marriage from the usual societal pattern cannot be considered as a defiance of contemporary social mores.”

Source: Chua-Qua v Clave, G.R. No. 49549 (1990)

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