ISIDRO CARIÑO v. COMMISSION ON HUMAN RIGHTS

FACTS:

The case involves a special civil action of certiorari and prohibition filed by the Solicitor General. The main issue is whether the Commission on Human Rights (CHR) can take cognizance of a case and grant relief when the relief sought involves the review and reversal or modification of a decision or order issued by a court or government agency exercising quasi-judicial functions. The facts of the case are as follows:

On September 17, 1990, around 800 public school teachers, including members of the Manila Public School Teachers Association (MPSTA) and the Alliance of Concerned Teachers (ACT), undertook "mass concerted actions" to highlight their grievances. These actions involved staying away from their classes, gathering in peaceable assemblies, and converging at Liwasang Bonifacio. The teachers demanded negotiations with the government to address their concerns, which they claimed had been repeatedly ignored. Despite orders from the Secretary of Education to return to work or face dismissal, the mass actions continued, with more teachers joining in the following days.

Among the teachers who participated in the mass actions were the eight private respondents in this case, who were teachers at the Ramon Magsaysay High School in Manila. They supported the non-political demands of the MPSTA.

After failing to comply with the return-to-work order, the private respondents were administratively charged and given five days to answer the charges. They were also preventively suspended for 90 days and temporarily replaced. An investigation committee was formed to hear the charges in accordance with Presidential Decree 807.

In the administrative case (Case No. DECS 90-082), the respondents filed separate answers, opted for a formal investigation, and moved for the suspension of the proceedings pending resolution by the Supreme Court of their application for an injunctive writ or temporary restraining order. However, their motion for suspension was denied, and when their motion for reconsideration was also denied, the respondents boycotted the entire proceedings. The case resulted in a decision by Secretary Cariño, dated December 17, 1990, dismissing Apolinario Esber from service and suspending Babaran, Budoy, and del Castillo for nine months.

Meanwhile, the MPSTA filed a petition for certiorari before the Regional Trial Court of Manila, which was later dismissed. The MPSTA also filed a similar petition before the Supreme Court. The ACT also filed a petition before the Supreme Court. Both petitions raised issues of due process and the right to peaceful assembly.

During this time, the respondent teachers submitted sworn statements to the Commission on Human Rights, complaining that they were replaced as teachers without notice while participating in peaceful mass actions.

The complaints of the teachers, along with those of other teachers who were suspended by the Department of Education, were docketed as "Striking Teachers CHR Case No. 90-775." The Commission scheduled a "dialogue" on October 11, 1990, and subpoenaed Secretary Cariño to attend.

The Commission on Human Rights (CHR) received a subpoena served at its office regarding a case involving 42 teachers who were suspended without formal notice for not joining a mass leave. The complainants' counsel expressed that the teachers were denied due process and unjustly suspended. The CHR issued an order requiring Secretary Isidro Cariño, Dr. Erlinda Lolarga, and the principal of Ramon Magsaysay High School to appear and explain the allegations. Secretary Cariño filed a motion to dismiss the case, stating that the complaint had no cause of action and that the CHR had no jurisdiction. Pending the determination of the motion to dismiss, judgments were rendered in two other cases involving the striking teachers. The CHR denied the motion to dismiss and required the respondents to submit their counter-affidavits. The CHR asserted its intention to hear and decide the case on the merits despite the Supreme Court's joint resolution in other related cases. The Solicitor General, representing Secretary Cariño, filed a petition for certiorari and prohibition to invalidate the CHR's order.

ISSUES:

  1. Whether or not the Commission on Human Rights has jurisdiction to adjudicate the issues of whether the striking teachers were denied due process and if the grievances justify their strike.

  2. Whether or not the Commission on Human Rights has the power to function as another court or quasi-judicial agency in the country.

  3. Whether the Commission on Human Rights (CHR) has the power to try and resolve on the merits the matters involved in the case at hand, particularly the disciplinary proceedings against the teachers conducted by the Department of Education (DECS).

  4. Whether the matters involved in the case pertain to the original jurisdiction of the Secretary of Education and the appellate jurisdiction of the Civil Service Commission.

  5. Whether or not the investigation by the Commission on Human Rights (CHR) in the administrative cases against the teachers would serve any useful purpose.

  6. Whether or not the CHR has the power to reverse the conclusions of the Education Secretary in the said administrative cases.

RULING:

  1. The Court declares that the Commission on Human Rights does not have the power to adjudicate the aforementioned issues and that it was not meant to be another court or quasi-judicial agency in the country. The Commission's power is limited to investigating human rights violations involving civil and political rights, but it does not have the authority to apply the law to factual conclusions and decide controversies authoritatively, finally, and definitively.

  2. The CHR does not have the power to try and resolve on the merits the matters involved in the case, including the disciplinary proceedings against the teachers. The CHR's power is limited to investigation and it does not have the authority to adjudicate or adjudge cases. The matters in question are within the original jurisdiction of the Secretary of Education and the appellate jurisdiction of the Civil Service Commission.

  3. The petition is granted. The Order of December 29, 1990, which allowed the CHR to hear and resolve the administrative cases against the teachers, is annulled and set aside. The CHR and its Chairman and Members are prohibited from hearing and resolving the case on the merits.

PRINCIPLES:

  • The Commission on Human Rights has the power to investigate all forms of human rights violations involving civil and political rights.

  • Fact-finding is not adjudication, and the authority to apply the law to factual conclusions is necessary for a judicial function.

  • The Commission on Human Rights cannot duplicate or take over the functions of the courts or quasi-judicial agencies.

  • The power of the CHR is limited to investigation and does not extend to adjudicating or resolving disputes.

  • The terms "investigate" and "adjudicate" have distinct meanings. Investigation refers to the search for information and the gathering of evidence, while adjudication pertains to the settlement or resolution of a controversy by applying the law to the facts established during the investigation.

  • Matters within the scope of the disciplinary powers granted to the Secretary of Education under the Civil Service Law and within the appellate jurisdiction of the Civil Service Commission should be resolved by those bodies. The CHR has no authority to intrude into their jurisdiction.

  • The investigation by the CHR would serve no useful purpose if its conclusions are contrary to the Education Secretary's conclusions. The CHR has no power to reverse the Secretary's conclusions.

  • The power to reverse the Education Secretary's conclusions lies with the Civil Service Commission and ultimately, with the Supreme Court.

  • The CHR cannot arrogate unto itself the appellate jurisdiction of the Civil Service Commission.