In a decision that clarifies the extent of a teacher’s discretion in grading and the due process requirements for employment termination, the Supreme Court held that a teacher’s act of tampering with student records constituted serious misconduct, justifying her dismissal. The Court emphasized that while teachers have some leeway in assessing student performance, alterations to official records without proper justification and in violation of school regulations are grounds for termination. This ruling reinforces the importance of maintaining the integrity of academic records and adhering to due process when addressing teacher misconduct.

Grading Discretion vs. Record Integrity: When Can a Teacher Be Dismissed for Tampering with Grades?

The case of Colegio de San Juan de Letran v. Isidra Dela Rosa-Meris (G.R. No. 178837, September 1, 2014) arose from complaints lodged by parents against Isidra Dela Rosa-Meris, a teacher at Colegio de San Juan de Letran. The parents alleged that Dela Rosa-Meris was indifferent to their concerns and questioned the accuracy of student grades. An investigation revealed discrepancies between Dela Rosa-Meris’s “Dirty Records” (unofficial grade book) and “Clean Records” (official grade book), with alterations and erasures made without proper documentation. Consequently, the school issued a notice of charge, but Dela Rosa-Meris refused to provide an explanation, leading to her termination. She then filed a complaint for illegal dismissal.

The Labor Arbiter (LA) initially ruled in favor of the school, finding the dismissal valid due to the grade tampering. The National Labor Relations Commission (NLRC) initially modified the decision, ordering separation benefits but without backwages, before ultimately reversing itself and affirming the LA’s decision. The Court of Appeals (CA), however, sided with Dela Rosa-Meris, finding her dismissal illegal. The Supreme Court then took on the case to resolve whether the CA erred in finding grave abuse of discretion on the part of the NLRC when it upheld Dela Rosa-Meris’s dismissal, focusing on both procedural and substantive aspects of the case.

The Supreme Court first addressed the procedural issue of whether the CA erred in overturning the NLRC’s dismissal of Dela Rosa-Meris’s appeal due to her failure to attach a certification of non-forum shopping. The Court emphasized the importance of adhering to procedural rules. The court stated that:

SECTION 4. REQUISITES FOR PERFECTION OF APPEAL. a) The Appeal shall be filed within the reglementary period as provided in Section 1 of this Rule; shall be verified by appellant himself in accordance with Section 4, Rule 7 of the Rules of Court, with proof of payment of the required appeal fee and the posting of a cash or surety bond as provided in Section 6 of this Rule; shall be accompanied by memorandum of appeal in three (3) legibly typewritten copies which shall state the grounds relied upon and the arguments in support thereof, the relief prayed for, and a statement of the date when the appellant received the appealed decision, resolution or order and a certification of non-forum shopping with proof of service on the other party of such appeal. A mere notice of appeal without complying with the other requisites aforestated shall not stop the running of the period for perfecting an appeal.

According to the court, Dela Rosa-Meris’s explanation for the lack of certification was unacceptable. It also cannot be considered as a special circumstance or compelling reason that would justify tempering the hard consequence of the procedural requirement on non-forum shopping. Consequently, the Court found that the NLRC correctly dismissed Dela Rosa-Meris’s appeal, rendering the LA’s decision final and executory.

Even if the procedural flaws were disregarded, the Supreme Court proceeded to examine the merits of the case. The central issue was whether Dela Rosa-Meris was justified in making erasures and alterations to student grades, and whether she followed proper procedures in doing so. Dela Rosa-Meris argued that the alterations were due to student improvements within the grading period and that the “Dirty Records” were merely rough drafts. However, the Court found these explanations unconvincing.

The Court pointed to the fact that the alterations were made after the Clean Records had already been reviewed and approved by subject coordinators. In their testimonies, the subject coordinators for Physical Education, Music & Arts, and Writing categorically stated that the alterations and erasures of grades in the Clean Records were made after they had checked and approved the said grades. Furthermore, the NLRC observed that it was unlikely for students to show significant improvements within such a short period to justify such a big adjustment of the final grades in the first quarter.

The Court emphasized the importance of maintaining accurate and unaltered records. Citing the school’s Faculty Manual, it stated that erasures in class records should bear the initials of the teacher concerned, a procedure that Dela Rosa-Meris failed to follow. According to the Court, the purpose of this procedure is to obviate any room for confusion or issue on the objectivity of the grading system.

The Court highlighted the discrepancy between the entries in the “Dirty Record Book” and “Clean Record Book”. It emphasized that Clean Record Book should be no less different than that which appears in the original, otherwise known as “dirty record book”. Any discrepancy reasonably yields the conclusion that the change was not premised on an objective assessment of the performance of a student. For this reason alone, respondents may not be faulted for administratively proceeding against the complainant.

The Supreme Court also addressed Dela Rosa-Meris’s argument that she had the right to give grades she felt students deserved. The Court clarified that while teachers have some discretion, it is not unlimited and must be based on justifiable grounds, as required by Section 79 of the Manual of Regulation for Private Schools:

Sec. 79. Basis for Grading. 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.

The Court found Dela Rosa-Meris’s actions to be a violation of school rules and regulations, constituting serious misconduct under Article 282(a) of the Labor Code and Section 94(b), Article XVII of the Manual of Regulations for Private Schools, which allows for the termination of a teacher’s employment for negligence in keeping school or student records, or tampering with or falsification of the same. Moreover, the Court stressed that respondent is no ordinary employee. She carries with her a responsibility like no other. She is expected to be an exemplar of uprightness, integrity and decency, not only in the school, but also in the larger community. She is a role model for her students.

Finally, the Supreme Court determined that the school had complied with due process requirements in terminating Dela Rosa-Meris’s employment. The school had provided her with written notices specifying the grounds for termination, giving her an opportunity to explain her side and conducting a conference. Despite these opportunities, Dela Rosa-Meris refused to present her side, thus waiving her right to be heard. As a result, the Court ruled that Dela Rosa-Meris was dismissed for a just cause and in accordance with due process, making her ineligible for reinstatement, separation pay, backwages, or damages.

FAQs

What was the central issue in this case?	The central issue was whether a teacher’s actions of altering student grades constituted just cause for termination of employment, and whether the school followed due process in the termination. The court also took note of Dela Rosa-Meris’s failure to comply with the procedural rules for filing an appeal.
What did the school investigation reveal?	The investigation revealed discrepancies between the teacher’s “Dirty Records” and “Clean Records,” with alterations and erasures made without proper documentation, indicating potential grade tampering.
What was the teacher’s defense against the charges?	The teacher argued that the alterations were due to student improvements within the grading period and that the “Dirty Records” were merely rough drafts and not final.
Why did the Supreme Court reject the teacher’s defense?	The Court found her explanations unconvincing, pointing to the fact that the alterations were made after the official records had been reviewed and approved by subject coordinators, and the lack of proper documentation for the changes.
What is the significance of the “Dirty Records” in this case?	The “Dirty Records,” although seemingly unofficial, were considered an important reference for student performance, and alterations without proper initials violated school policy.
What does the Manual of Regulations for Private Schools say about grading?	Section 79 of the Manual states that grades should be based on a student’s scholastic record, and any additions or diminutions to the grade should not be allowed without proper justification.
What constitutes serious misconduct in this context?	Knowingly and deliberately falsifying one’s records by changing the submitted record and the supporting documents relevant thereto is not only a school violation but a serious misconduct.
What due process steps must an employer take when terminating employment?	The employer must give the employee a written notice specifying the grounds for termination, provide a reasonable opportunity to explain their side, conduct a hearing or conference, and give a written notice of termination indicating the grounds for justification.
Why was the teacher deemed to have been afforded due process in this case?	Despite opportunities to explain her actions, the teacher refused to cooperate, failing to defend herself against the charges of tampering with official records.

The Supreme Court’s decision in Colegio de San Juan de Letran v. Isidra Dela Rosa-Meris underscores the importance of maintaining the integrity of academic records and adhering to due process in employment termination. Teachers have some discretion in assessing student performance, but alterations to official records without proper justification and in violation of school regulations are grounds for termination. This ruling serves as a reminder to educators to uphold ethical standards in grading and documentation.

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: Colegio de San Juan de Letran v. Isidra Dela Rosa-Meris, G.R. No. 178837, September 1, 2014