Rizza R. Cabrera Dr.

Maville Alastre-Dizon
CTP 7-3

CASE ANALYSIS

I. SUMMARY
COLEGIO DE SAN JUAN DE LETRAN, Petitioner, vs ISIDRA DELA ROSA-MERIS, Respondent.
SUPREME COURT Republic of the Philippines
Manila THIRD DIVISION
G.R. No. 178837 September 1, 2014

The Court GRANTS the petition and REVERSES The Decision of the Court of Appeals in CA-G.R.
SP No. 92933, dated January 29, 2007 and its Resolution dated May 25, 2007, and REINSTATES
the Resolution of the National Labor Relations Commission, dated November 18, 2005 which
dismissed the appeal of respondent Isidra Dela Rosa-Meris.
FACTS.
Petitioner Colegio De San Juan de Letran is a religious educational institution operated by
the Order of Preachers. Respondent Isidra Dela Rosa-Meris was hired by petitioner in January
1971 as a probationary trial teacher until she became Master Teacher in June 1982. The rift
between petitioner, Colegio De San Juan de Letran and respondent, Isidra Dela Rosa-Meris
began on September 10, 2003, when several parents of the Preparatory (Prep) pupils who were
under the class of respondent went to the Principal’s Office to lodge a complaint against
respondent, alleging the following: (1) respondent has been too indifferent and unprofessional
in addressing their concerns; and (2) the pupil who landed in the top of the Honor Roll, Louis
Ariel Arellano, seemed not to be the best pupil in class. Relying on such theories, said parents
then asked for the formula in the computation of the general average.
Oct. 6, 2003, respondent Isidra Dela Rosa-Meris started a complaint against petitioner
Letran College–Manila for illegal dismissal and damages before the Labor Arbiter (LA). The LA
rendered a decision dated May 14, 2004 finding the dismissal of respondent valid and legal. On
appeal to the National Labor Relations Commission (NLRC), the LA decision was modified by
ordering the petitioner to pay the respondent separation pay benefits in lieu of reinstatement
without backwages at the rate of one month’s salary for every year of service. Both parties
moved for reconsideration. In its decision dated Nov. 18, 2005, the NLRC made a complete
turnabout of its previous stance, ruling that the respondent’s appeal was not perfected due to
lack of certification of non-forum shopping. The Court of Appeals (CA) reversed and set aside
the decision of the NLRC and granted the petition filed by the respondent.

II. LEGAL FOUNDATION APPLIED

The respondent Isidra Dela Rosa-Meris had committed a misconduct, serious enough to
warrant her dismissal from employment under paragraph (a) of Article 282 of the Labor Code,
as well as Section 94(b), Article XVII of the Manual of Regulations for Private Schools, which
provides that the employment of a teacher may be terminated for negligence in keeping school
or student records, or tampering with or falsification.

Also in Section 79 Basis for Grading of the Manual of Regulation for Private Schools says the
final grade or rating given to a pupil or student in a subject should be based on his scholastic
record. Any addition or diminution to the grade x x x shall not be allowed.

Under Sec. 9 of the MAGNA CARTA FOR PRIVATE SCHOOL TEACHERS, No private school
teacher shall be dismissed by the school except for cause and the proper observance of due
process. In the case above, the petitioner directed respondent to explain why no disciplinary
action should be taken against her for tampering her class records, through a letter but she
refused to receive. It is clear that respondent refused to present her side by choice. It can be
said that ample opportunity was afforded to respondent to defend herself from the charges
levelled on her, but she opted not to take it.

The respondent Isidra Dela Rosa-Meris violated the following in the Code of Ethics of
Professional Teacher
  Article VI: The Teacher and Higher Authorities in the Profession
Section 1. Every teacher shall make it his duty to make an honest effort to understand
and support the legitimate policies of the school and the administration regardless of
personal feeling or private opinion and shall faithfully carry them out.
The teacher disregarded the policy of the school with the offense of tampering of class
records as stated on the Elementary Faculty Manual of the Colegio.
 Article IX: The Teachers and the Parents
 Section 3. A teacher shall hear parent’s complaints with sympathy and understanding,
and shall discourage unfair criticism.
The teacher has been indifferent and unprofessional when the parents questioned the
grades of the Honor Student.

III. REFLECTION/ REACTION

As teachers, we should establish and maintain good relationship with school officials, teachers,
other personnel including learners and their parents. If conflict arise, it should be given proper
attention and exercise professionalism in addressing any concern. In the case stated above, the
parents raise their concern to higher authority because the teacher acted indifferently. As
future teacher, I shall not commit acts of dishonesty and be mindful of the policies and
procedures. It is my duty to determine academic marks fairly without bias. I will provide
complete and clean records and make sure it is readily available to persons with concern. If
there will be a need to alter the grades it should always be justified and according to existing
policies to avoid falsification.

It will be my duty to make honest effort to understand the policies of the school and
administration. I should maintain professional courtesy to school officials, teachers and other
personnel. I will refrain from serious misconduct and willful disobedience to avoid termination
of employment. But sometimes we can’t please everybody so conflicts arise. If in case it is not
settled, we should be aware of our rights to appeal to proper authorities.