G.R. No. 95445 & G.R. No. 95590; August 6, 1991
MANILA PUBLIC SCHOOL TEACHERS ASSOCIATION, et al. vs. HON. PERFECTO LAGUIO JR., et al. / ALLIANCE OF CONCERNED TEACHERS (ACT), et al. vs. HON. ISIDRO CARIÑO, et al.

FACTS

Public school teachers, members of petitioner associations, engaged in a “mass action” on September 17, 1990, a regular school day, by not conducting classes and instead holding assemblies to protest various grievances, including unpaid allowances and alleged government failures to prioritize education funding. Despite prior dialogues with government agencies, their demands remained unaddressed. Respondent Secretary of Education Isidro Cariño issued a return-to-work order and subsequently initiated administrative charges against participating teachers for grave misconduct, gross neglect of duty, and absence without leave, placing them under preventive suspension.
The petitioners filed cases challenging the administrative actions, arguing that their mass action was a legitimate exercise of their constitutional rights to peaceably assemble and petition the government for redress of grievances. They contended the charges and suspensions violated their rights without due process. The consolidated petitions sought to nullify the disciplinary proceedings.

ISSUE

Whether the public school teachers’ “mass action,” involving absence from their teaching duties on a school day, constitutes a protected exercise of constitutional rights, thereby rendering the subsequent administrative charges and preventive suspensions illegal.

RULING

The Supreme Court ruled against the petitioners, upholding the legality of the administrative charges and preventive suspensions. The Court clarified that while the Constitution guarantees the rights to peaceable assembly and petition, these rights are not absolute and must be exercised within the bounds of law. Government employees, including public school teachers, enjoy a diminished scope of these rights compared to private citizens due to the nature of public service.
The legal logic is grounded on the principle that the right of government employees to engage in concerted activities is circumscribed by their duty to uphold public service continuity. By deliberately abandoning their classes on a school day, the teachers engaged in an illegal strike, which is expressly prohibited for civil service personnel. Their action disrupted a vital public service—education—and constituted gross neglect of duty and conduct prejudicial to the best interest of the service. The administrative charges were a valid exercise of disciplinary authority. The preventive suspension was also justified as a precautionary measure pending investigation, not a penalty, to prevent the teachers from potentially influencing witnesses or committing further acts prejudicial to the service. The Court emphasized that redress of grievances must be sought through lawful means without compromising the delivery of essential public services.