HON. ISIDRO CARIÑO, in his capacity as Secretary of the Department of Education, Culture & Sports, DR. ERLINDA LOLARGA, in her capacity as Superintendent of City Schools of Manila, vs. THE COMMISSION ON HUMAN RIGHTS, GRACIANO BUDOY, JULIETA BABARAN, ELSA IBABAO, HELEN LUPO, AMPARO GONZALES, LUZ DEL…
- G.R. Number: G.R. No. 96681
- Promulgated: 1991-12-02
- Ponente: Narvasa, J.
Doctrine
Investigation is distinct from adjudication; an agency vested only with investigative power cannot act as a court or quasi-judicial body to adjudicate and resolve controversies on the merits.
Matters placed by law within the jurisdiction of courts or quasi-judicial agencies (e.g., administrative disciplinary proceedings) must be reviewed through the processes provided by those bodies and the ordinary appellate routes, not by the CHR exercising investigative functions.
Facts
The Solicitor General filed a special civil action of certiorari and prohibition questioning whether the Commission on Human Rights (CHR) may review and reverse or modify decisions or orders of courts or quasi-judicial agencies. (petition framing)
The petition's factual allegations were not denied by respondents and were taken as substantially correct for resolving the legal questions. (record posture)
CHR conducted a 'dialogue' hearing on a complaint by striking teachers, heard counsel's claims of denial of due process and sympathies for their grievances, and issued an Order intending to resolve the case. (CHR action)
The matters the CHR proposed to resolve included (1) whether striking teachers were denied due process and whether just cause existed for disciplinary sanctions, and (2) whether the grievances justified the strike. (matters framed for CHR determination)
Issues
Whether the Commission on Human Rights has the constitutional power to take cognizance of and grant relief that reviews, reverses or modifies decisions or orders issued by a court or quasi-judicial agency. (adjudicatory power)
Whether the CHR may try and resolve on the merits administrative disciplinary matters—such as alleged denial of due process in disciplinary proceedings—when those matters are within the jurisdiction of another agency or court. (scope vis-à-vis administrative discipline)
Ruling
The petition is granted: the CHR, which has only the power to investigate, lacks authority to try and decide cases like courts or quasi-judicial bodies; it cannot adjudicate or resolve matters on the merits as to Striking Teachers HRC Case No. 90-775. The CHR's Order of 29 December 1990 is annulled and set aside. (disposition)
Questions whether disciplinary conclusions were supported by substantial evidence, whether proceedings were void for lack of due process, or whether the Secretary committed human-rights violations are matters proper for motion for reconsideration, administrative review (Civil Service Commission), and eventual Supreme Court review—not CHR adjudication.
Keywords
G.R. No. 96681, Special civil action of certiorari and prohibition, Commission on Human Rights (CHR), Jurisdiction, Quasi-judicial functions, Administrative charges, P.D. 807, Preventive suspension, Due process, Peaceable assembly, Return-to-work order, Striking Teachers CHR Case No. 90775, Department of Education, Culture & Sports (DECS), Article 1191 Civil Code, Mortgagee in good faith, Piercing the corporate veil, G.R. No. 95445, G.R. No. 95590, commission, motion