G.R. No. 96681 December 2, 1991
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, petitioners, vs. THE COMMISSION ON HUMAN RIGHTS, GRACIANO BUDOY, JULIETA BABARAN, ELSA IBABAO, HELEN LUPO, AMPARO GONZALES, LUZ DEL CASTILLO, ELSA REYES and APOLINARIO ESBER, respondents.

FACTS

Public school teachers, including the private respondents, participated in mass concerted actions in September 1990, which involved absences from their classes to highlight grievances. The Secretary of Education, petitioner Isidro Cariño, issued a return-to-work order and subsequently initiated administrative proceedings against non-complying teachers. The private respondents were preventively suspended and faced formal charges. An investigation committee was formed under P.D. 807, and after proceedings where the respondents eventually walked out, Secretary Cariño rendered a decision dismissing one teacher and suspending others.
During the pendency of these administrative proceedings, the affected teachers also filed a complaint with the Commission on Human Rights (CHR). They alleged their suspensions and replacements were effected without due process. The CHR assumed jurisdiction, conducted hearings, and issued an order directing the DECS to reinstate the teachers and cease further disciplinary proceedings. The CHR asserted it could investigate all forms of human rights violations involving civil and political rights.

ISSUE

May the Commission on Human Rights take cognizance of and adjudicate upon matters involving the review, reversal, or modification of decisions issued by a government agency exercising quasi-judicial functions?

RULING

No. The Supreme Court ruled that the CHR possesses no adjudicatory powers and cannot review or reverse decisions of courts or quasi-judicial agencies. The Court clarified the constitutional mandate of the CHR under Article XIII, Sections 17 and 18. Its primary function is investigatory. It is empowered to investigate all forms of human rights violations, but such investigation is distinct from adjudication. To investigate is to inquire, examine, or look into for the purpose of discovering facts. In contrast, to adjudicate is to settle or determine a controversy judicially, involving the exercise of judicial discretion leading to a binding judgment.
The administrative case against the teachers was within the exclusive jurisdiction of the Department of Education, Culture and Sports, as the office vested by law with quasi-judicial authority over disciplinary matters concerning public school teachers. The CHR, by ordering reinstatement and halting the DECS proceedings, effectively reviewed and set aside the Secretary’s decision, thereby exercising a power of adjudication it does not possess. While the CHR can investigate the alleged human rights aspects of the case, its authority ends with fact-finding, recommendation, or the filing of appropriate legal or administrative actions before the proper bodies. It cannot itself issue a ruling that supplants the judgment of the competent agency.