**Fabella v. Court of Appeals: Safeguarding Due Process in Administrative Proceedings**
### Facts:
The case originated when DECS Secretary Isidro Cariño issued a return‐to‐work order to public school teachers following their participation in strikes for various demands. Subsequently, administrative charges were brought against the petitioners, accusing them of participating in unauthorized mass actions, leading to their preventive suspension. The charges encompassed grave misconduct, gross neglect of duty, gross violation of civil service laws and regulations, refusal to perform official duty, conduct prejudicial to the best interest of service, and absence without official leave (AWOL).
The teachers sought recourse through an injunctive suit (Civil Case No. 60675) at the Regional Trial Court in Quezon City to halt the investigation and any resulting decisions, which was initially denied. They then amended their complaint to a writ of certiorari and mandamus, arguing that the investigating committee imposed the burden of proof on them unjustly. Following unsuccessful attempts to have their case entertained properly, including being declared in default during proceedings and the failure of Secretary Cariño to attend court-mandated appearances, the teachers faced dismissal based on the committee’s findings.
The matter escalated to the Supreme Court after the teachers’ appeal was taken from the trial court’s unfavorable decision and the subsequent affirmation by the Court of Appeals of that decision.
### Issues:
1. Whether the Court of Appeals erred in holding that private respondents were denied due process of law.
2. Whether the Court of Appeals erred in applying Section 9 of RA 4670 – Magna Carta for Public School Teachers – regarding the composition of the investigating committee.
3. Whether the appeal was dismissed by the Court of Appeals in error and whether its affirmation of the trial court’s decision was in grave abuse of discretion.
### Court’s Decision:
The Supreme Court denied the petition, upholding the decision of the Court of Appeals. It was determined that the private respondents were indeed denied due process in the course of the administrative proceedings against them. Key findings included the improper composition of the committees formed to investigate the charges against the teachers, which did not comply with the provisions of RA 4670, specifically Section 9, which mandates the inclusion of a representative from a teacher’s organization in the committee. The Court held that the absence of such representative rendered the proceedings and its consequent actions void for lack of competent jurisdiction.
The Court further endorsed the applicable due process in administrative proceedings, establishing that due process was not observed as the committees constituted violated the teachers’ right to a fair hearing by an impartial tribunal as prescribed under RA 4670.
### Doctrine:
This case reiterated the importance of due process in administrative proceedings, emphasizing the necessity of adhering to the specific procedural requirements laid down in special statues like RA 4670 regarding the disciplinary actions against public school teachers.
### Class Notes:
– **Due Process in Administrative Proceedings**: Requires notice, an opportunity to be heard, a tribunal with competent jurisdiction, and a decision based on substantial evidence.
– **RA 4670 (Magna Carta for Public School Teachers)**: Section 9 specifies the composition of committees investigating administrative charges against teachers, emphasizing the need for a representative from a teacher’s organization for a fair and impartial hearing.
– **Doctrine of Statutory Construction**: A special law is not overridden by a later general law unless clearly intended. RA 4670 is not repealed or altered implicitly by PD 807 as they can coexist.
### Historical Background:
The case underscores the conflict between administrative authority and the rights of public school teachers as government employees, set within the broader context of legal protections provided by RA 4670 against disciplinary actions without due process. This decision highlights the judiciary’s role in upholding due process rights and statutory protections for specific sectors, reiterating the non-subsumption of special laws by general ones without explicit legislative intent.
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