G.R. No. 96681 - Carino vs. Commission on Human Rights

Background and administrative actions
On September 17, 1990, about 800 public school teachers, including members of the Manila Public School Teachers Association (MPSTA) and the Alliance of Concerned Teachers (ACT), stayed away from classes and held assemblies at Liwasang Bonifacio to press grievances after failed negotiations with the Department of Education, Culture & Sports (DECS).
Secretary Isidro Carino issued a return-to-work order with 24-hour compliance and directed DECS officials to initiate dismissal proceedings under P.D. 807. Forty-two teachers were preventively suspended for 90 days and charged in DECS Case No. 90-082.

DECS and Supreme Court proceedings
The charged teachers filed separate answers, opted for formal investigation, and walked out when their motion to suspend administrative proceedings was denied. On December 17, 1990, Carino’s decision dismissed Apolinario Esber and suspended Julieta Babaran, Graciano Budoy, and Luz del Castillo for nine months.
The MPSTA and ACT filed certiorari petitions in the Regional Trial Court of Manila, which were elevated to the Supreme Court as G.R. Nos. 95445 and 95590. On August 6, 1991, the Court dismissed both petitions “without prejudice to any appeals” to the Civil Service Commission.

CHR investigation and challenged order
On September 27, 1990, the suspended teachers filed complaints with the Commission on Human Rights (CHR), docketed as Striking Teachers CHR Case No. 90-775. The CHR scheduled a “dialogue” on October 11, 1990, and subpoenaed Sec. Carino to appear on October 19, 1990.
On December 28, 1990, the CHR denied Carino’s motion to dismiss and ordered him and Supt. Erlinda Lolarga to submit counter-affidavits within ten days, declaring its intention to “hear and resolve the case on the merits.”

Jurisdictional scope
Whether the CHR may review, modify, or reverse decisions or orders issued by a court of justice or a government agency exercising quasi-judicial functions.

Constitutional mandate
Whether the CHR’s constitutionally enumerated powers permit it to adjudicate human rights violations in cases where trial and adjudication lie within the jurisdiction of other judicial or quasi-judicial bodies.