Title
Supreme Court
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 Summary (G.R. No. 216930)

Key Legislation and Issuances

– Republic Act No. 10157 (Kindergarten Education Act) mandates one year of compulsory kindergarten.
– Republic Act No. 10533 (Enhanced Basic Education Act of 2013 or “K to 12 Law”) extends basic education from ten to thirteen years (one year kindergarten, six years elementary, four years junior high, two years senior high).
– Implementing rules and regulations issued by DepEd (e.g., DO No. 31), CHED (CMO No. 20), DOLE and TESDA (Joint Guidelines) address curriculum, teacher qualifications, labor-management issues and transition concerns.

Historical Evolution of Philippine Basic Education

From Act No. 74 (1901) establishing public primary instruction, through the 1935 and 1973 Constitutions guaranteeing free primary (and, where feasible, secondary) education, to the 1987 Constitution (which made elementary education compulsory and both elementary and high school free). Subsequent laws (RA 6655, RA 6728/8545) provided free public secondary education and vouchers for private high school. RA 9155 (2001) defined basic education to include early childhood, elementary, high school and alternative learning systems.

Enactment of the Kindergarten Education Act

RA 10157 (2012) institutionalized one year of preparatory kindergarten for children at least five years old, making it compulsory before Grade 1 and mandating Mother Tongue-Based Multilingual Education (MTB-MLE) in kindergarten.

Enactment of the K to 12 Law

RA 10533 (2013) responded to international standards (10-year system in only three countries pre-2013), decongested the curriculum, introduced spiral progression, added two years of senior high, expanded MTB-MLE (K–Grade 3), and provided for specialization pathways and public-private partnerships (vouchers for eligible senior high students). It tasked DepEd, CHED, TESDA and DOLE to issue IRRs to address transition, infrastructure, manpower, and labor welfare.

Implementing Rules and Joint Guidelines

– DepEd Order No. 31 (2012) guided phased implementation of Grades 1–10 curriculum.
– K to 12 IRR (2013) detailed voucher implementation, stakeholder consultations, labor management provisions (Joint Guidelines issued May 2014 by DOLE/DepEd/CHED/TESDA).
– CHED Memorandum Order No. 20 (2013) revised General Education curriculum for higher education to 36 units (24 core, 9 elective, 3 Rizal).

Consolidated Petitions and Procedural Posture

Seven petitions under Rule 65 challenged constitutionality of RA 10157, RA 10533 and related issuances. TRO issued in one case (CMO No. 20’s exclusion of Filipino courses); preliminary injunctions denied in others. Memoranda submitted April 2016.

Issues Presented

Procedural: Justiciability, standing, proper remedies (certiorari, prohibition, mandamus).
Substantive: Validity of enactment, alleged undue delegation, conflict with 1987 Constitution (education, language, culture, academic freedom, labor rights), due process, equal protection.

Judicial Review and Remedies

The Court has authority to settle actual controversies and correct grave abuse of discretion by coequal branches. Political questions do not bar review of constitutional violations. Certiorari/prohibition may extend beyond judicial or quasi-judicial acts to redress grave abuses. Four requirements: (1) actual case or controversy; (2) petitioner’s standing; (3) earliest opportunity; (4) constitutional question central to the dispute.

Justiciability: Case or Controversy and Ripeness

There is an actual controversy and ripeness: the K to 12 Program is in effect, students are enrolled and parents/teachers/institutions are directly affected (curriculum change, two extra years, voucher implementation, faculty transition).

Justiciability: Standing

Petitioners include citizens, taxpayers (challenging disbursement of public funds), organizations representing faculty and staff (authorized by members), legislators defending legislative prerogatives, and class-action plaintiffs (students, parents, teachers). Their asserted injuries (job displacement, tuition burden, curriculum exclusion) confer standing.

Statutory Enactment: Consultations and Enrolled Bill Doctrine

Extensive DepEd and congressional regional consultations preceded the laws. The enrolled bill doctrine bars inquiry beyond authenticated enrolled copy. No evidence of signature withdrawal or text discrepancy.

Statutory Enactment: Delegation of Legislative Power

RA 10533 sets clear policy objectives, standards for curriculum, teacher training/hiring, transition strategy. It passes both the completeness and sufficient-standards tests for permissible delegation to DepEd, CHED, TESDA, DOLE.

Validity of DepEd Order No. 31

DO No. 31 implements Grades 1–10 curriculum pending full K to 12 rollout. It is grounded in DepEd’s constitutional mandate to formulate and implement basic education policy. Internal regulations need not undergo publication or registration with the National Administrative Register.

Police Power and Education Regulation

Education regulation falls under the State’s police power to promote general welfare. State may impose reasonable controls on basic education’s scope and duration consistent with Wisconsin v. Yoder’s balancing of state interest and individual rights.

Compulsory and Free Basic Education

1987 Constitution makes elementary compulsory (K–Grade 6) and free through high school. RA 10157 and RA 10533 did not narrow this mandate; rather, they affirmed compulsory elementary and expanded to universal kindergarten and free senior high, consistent with UDHR, ICESCR, CRC. Vouchers do not privatize public provision but improve access through public-private partnership.

Equal Protection and Substantive Due Process

Classification for compulsory senior high and MTB-MLE is rationally related to legislative aims of decongested, internationally aligned curriculum and mother-tongue development. Means (two extra years, spiral curriculum, MTB-MLE) are not unduly oppressive; they serve public interest in quality, competitive education; alternative less intrusive measures (higher teacher pay, infrastructure) were weighed by policy-making branches.

Medium of Instruction and MTB-MLE

Article XIV, Sections 6–7 allow Filipino and English as primary media, with regional languages as auxiliary instruction. Congress lawfully mandated MTB-MLE (K–Grade 3). Constitutional policy on language is self-executory but does not limit legislative prerogative to expand auxiliary instruction to primary medium in early grades.

Academic Freedom and Labor Rights

Faculty academic freedom carries no immu

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