Title
Council of Teachers and Staff of Colleges and Universities of the Philippines vs. Secretary of Education
Case
G.R. No. 216930
Decision Date
Oct 9, 2018
Petitioners challenged RA 10533 (K-12 law) on constitutional grounds, citing education, labor, and cultural concerns. The Supreme Court upheld the law, ruling it valid and within the State's duty to improve education.

Case Digest (G.R. No. 216930)
Expanded Legal Reasoning Model

Facts:

  • Parties and Petitions
    • Petitioners: various teachers’ unions, faculty and staff associations of colleges/universities, students, parents, legislators, and concerned citizens.
    • Respondents: Department of Education (DepEd), Commission on Higher Education (CHED), Department of Labor and Employment (DOLE), Technical Education and Skills Development Authority (TESDA), other executive officials, and some private schools.
  • Legislation and Issuances Challenged
    • Republic Act No. 10533 (“K to 12 Law”): expands basic education from 10 to 13 years (kindergarten + 6 elementary + 4 junior high + 2 senior high).
    • Republic Act No. 10157 (“Kindergarten Education Act”): makes kindergarten compulsory, medium of MTB-MLE (mother-tongue-based multilingual education).
    • Department of Education Order No. 31, s. 2012: implements Grades 1–10 curriculum under K to 12.
    • CHED Memorandum Order No. 20, s. 2013: revises General Education Curriculum (GEC) for colleges (36 units).
    • K to 12 Implementing Rules & Regulations (2013) and Joint Guidelines with DOLE on labor-management in education.
  • Procedural History
    • Multiple petitions filed under Rule 65 (G.R. Nos. 216930, 217451, 217752, 218045, 218098, 218123, 218465).
    • Some TROs issued; later consolidated for full-merit review.
    • Solicitor General and private respondents opposed on grounds of justiciability, standing, and constitutionality.

Issues:

  • Procedural Issues
    • Justiciability: Is there an “actual case or controversy”?
    • Standing: Do petitioners (taxpayers, citizens, legislators, associations) have personal, direct injury or represent those who do?
    • Proper remedy: Are certiorari, prohibition, and mandamus appropriate to challenge laws and issuances?
  • Substantive Issues
    • Valid enactment: Was the K to 12 Law duly passed? Any undue delegation?
    • Enabling issuances: Are DO 31, K to 12 IRR, CMO 20, and Joint Guidelines within statutory and constitutional bounds?
    • Constitutional conflicts raised:
      • Education doctrines—free, compulsory elementary/high school; accessible, quality education at all levels.
      • Parents’ right to rear children.
      • Right to select profession or course of study.
      • Language provisions—the use of Filipino, English, and regional languages as instructional media.
      • Academic freedom; labor rights, security of tenure.
      • Due process, equal protection.
    • Alleged violations of special laws: RA 7104 (Commission on the Filipino Language), BP 232 (Education Act of 1982), RA 7356 (NCAA law).
    • Policy arguments: K to 12 costs, resource gaps, poverty, teacher pay, student-teacher ratios, employability.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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