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MANILA PUBLIC SCHOOL TEACHERS ASSOCIATION v. PERFECTO LAGUIO

FACTS:

The case involves a series of events that started with a mass action undertaken by around 800 public school teachers on September 17, 1990. The teachers, including members of the petitioning associations, embarked on this action to protest the alleged failure of the public authorities to address their grievances. The petitions allege various grievances, such as the non-payment of allowances and the oversizing of classes, among others.

Prior to the mass action, the teachers had engaged in dialogues and conferences with government agencies but were unsuccessful in obtaining a favorable response. On September 17, 1990, the teachers did not conduct their classes and instead gathered at Liwasang Bonifacio and then proceeded to the National Office of the Department of Education, Culture, and Sports (DECS) for a whole-day assembly. Upon meeting with the Secretary of Education, they were warned of potential dismissal for participating in an unauthorized mass leave.

The mass actions continued in the following days, with additional teachers joining. The Secretary of Education reliefed 292 teachers who did not return to their classes, but later revoked the dismissal order and placed 56 of them under preventive suspension. The Secretary filed motu proprio administrative complaints against the teachers who took part in the mass actions and placed them under 90-day preventive suspension. An investigating committee was subsequently constituted, and special prosecutors were designated to handle the prosecution during formal hearings. On October 11, 1990, the Secretary rendered a decision finding 20 teachers guilty and dismissing them from office.

The case involves two consolidated cases filed by public school teachers challenging the return-to-work order and subsequent suspension or dismissal orders issued by the Secretary of Education. The teachers had participated in mass actions to protest the alleged failure of the government to implement laws and measures for their benefit.

The Regional Trial Court had previously declared the return-to-work order valid, but the teachers sought review in the Supreme Court. The teachers filed motions to withdraw as parties in one of the cases, stating that they would appeal to the Civil Service Commission instead. The Court denied the teachers' plea to restore the status quo ante and restrain further suspensions or administrative proceedings against them. The Court noted that the teachers had participated in unauthorized absences and mass actions, despite the return-to-work order issued by the Secretary of Education.

ISSUES:

  1. Whether or not the petitioners' right to due process was violated in the initiation, conduct, or disposition of the investigations against them.

  2. Whether or not the petitioners were dismissed solely based on unsworn reports without evidence of their failure to obey the return-to-work order.

  3. Whether or not the charge sheets failed to specify the particular charges or offenses allegedly committed.

  4. Whether or not some teachers were not furnished with sworn complaints, and others were suspended without any formal charges.

  5. Whether or not teachers who attempted to return within a reasonable time after notice of the return-to-work order were not accepted back.

  6. Whether the striking teachers were given due process in the administrative proceedings against them.

  7. Whether the preventive suspension imposed on the striking teachers was valid.

  8. Whether there was a denial of due process in the administrative proceedings

  9. Whether the petitioners should have taken part in the administrative proceedings instead of seeking immediate recourse to the Supreme Court

RULING:

  1. The issue of whether or not the petitioners' right to due process was violated is not ripe for adjudication by the Court. The allegations made by the petitioners regarding the denial of due process are disputed by the public respondents. The Court cannot resolve this factual issue in the exercise of its review jurisdiction. The public respondents have set forth their own version of events in their pleadings, denying the allegations made by the petitioners. Therefore, the Court cannot determine whether or not the petitioners' right to due process was violated based on the current state of the pleadings.

  2. The striking teachers were given due process in the administrative proceedings against them. They were served with suspension orders and charge sheets notifying them of the charges and giving them five days to file their answers. Although some teachers refused to receive the notice of charges, many of them submitted their answers to the administrative complaints. The DECS Special Task Force conducted investigations and hearings, allowing the striking teachers to explain their absences and reasons for joining the strike. The principals confirmed under oath the reports of absences and participation in the strike. Therefore, the striking teachers were afforded the opportunity to be heard and present their side.

  3. The preventive suspension imposed on the striking teachers was valid. The Education Secretary was authorized by law to impose preventive suspension pending investigation of administrative cases. The striking teachers were given suspension orders and were informed of the charges against them. They were also given the opportunity to answer the charges. The preventive suspension was imposed to ensure the smooth conduct of the investigation and to prevent the teachers from influencing potential witness or tampering with evidence. Therefore, the preventive suspension was within the bounds of the Education Secretary's authority and was justified given the circumstances.

  4. The Court held that the question of alleged denial of due process could not be determined because the facts upon which it would be based were still in issue and actively controverted. The Court emphasized that it is not its role to make determinations of disputed incidents as it is not a trier of facts. The petitioners' remedy was to participate in the administrative proceedings, assert and vindicate their rights, and then appeal to the Civil Service Commission if adjudged guilty.

  5. The Court ruled that the petitioners should have followed the proper order of recourse through the judicial hierarchy. They should have taken part in the administrative proceedings, appealed to the Civil Service Commission if necessary, and only then, if immediate recourse to judicial authority was believed necessary, apply to the Regional Trial Court. The Court emphasized that it is a court of last resort and its review jurisdiction is limited to resolving questions of law.

PRINCIPLES:

  • Employees in the public (civil) service do not have the right to strike, although they have the right to self-organization, to petition Congress for the betterment of employment terms and conditions, and to negotiate with appropriate government agencies for the improvement of working conditions not fixed by law.

  • The issue of whether or not a petitioner's right to due process was violated in administrative proceedings is a question of fact that must be proven by the petitioner.

  • The right to due process requires that parties in an administrative proceeding be given notice and an opportunity to be heard.

  • Preventive suspension may be imposed to ensure the unhampered conduct of an investigation and to prevent possible influence on potential witnesses or tampering with evidence.

  • The Court is not a trier of facts and cannot make determinations of disputed incidents.

  • Parties-litigant are duty-bound to observe the proper order of recourse through the judicial hierarchy.

  • The Court is a court of last resort and its review jurisdiction is limited to resolving questions of law.