Del Rosario: Administrative liability of a teacher in bigamy

A WOMAN married a professional teacher and had two children with him before she learned that he was previously married and also has two children from the said marriage. When she learned of this, she filed a criminal case for Bigamy and Abandonment against her husband. She also filed a complaint with the Professional Regulation Commission (PRC) when her husband failed to give support.

The Board of Professional Teachers of PRC found the husband administratively liable for immorality and dishonorable conduct and revoked his license as a professional teacher.

When the matter reached the Supreme Court, the Court ruled that the PRC had jurisdiction over the case because the PRC actually has concurrent jurisdiction with the Civil Service Commission and the Department of Education over administrative cases of immoral or dishonorable conduct.

The Supreme Court also affirmed that there was substantial evidence to show that the husband was guilty of immoral and dishonorable conduct. In his defense, the husband said that he had the erroneous belief that his first wife was already dead. He also asserted that there was no proof that his second marriage, which was contracted before he became a teacher, brought damage to the teaching profession.

However, the Supreme Court did not find sufficient reason to overturn the findings of the PRC. Further, the Supreme Court affirmed the penalty imposed by the PRC and declared that, “In the practice of his profession, he, as a licensed professional teacher, is required to strictly adhere to, observe and practice the set of ethical and moral principles, standards and values laid down in the aforesaid code. It is of no moment that he was not yet a teacher when he contracted his second marriage. His good moral character is a continuing requirement which he must possess if he wants to continue practicing his noble profession. In the instant case, he failed to abide by the tenets of morality. Petitioner kept his first marriage secret to his second wife. Unfortunately for him, his second wife discovered his true marital status which led to the filing of the administrative and criminal cases against him.” (Puse vs. Puse, G.R. 183678 [2010])
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