# Oppression Cases: How Principals Must Treat Teachers

Teachers can charge a principal with oppression, but it takes bad faith: Caberoy (2014) cleared a principal over delayed pay. Ten Supreme Court cases explained.

This is the Markdown copy of [Oppression Cases: How Principals Must Treat Teachers](https://nash.com.ph/blog/principal-oppression-teachers-cases), an article on the NASH Reviewer Blog by Mark Anthony Llego, published Oct 31, 2026, updated Nov 4, 2026. Topics: School leadership, Aspiring school heads. NASH Reviewer is an independent practice platform not affiliated with DepEd, BHROD, or NEAP.

Teachers can charge their principal with oppression. It is a grave administrative offense, and the first offense carries a suspension of six months and one day to one year. But the charge must be proved by substantial evidence, and the Supreme Court requires bad faith. In the leading case, [*Office of the Ombudsman v. Caberoy*](https://lawphil.net/judjuris/juri2014/oct2014/gr_188066_2014.html), G.R. No. 188066, October 22, 2014 (Third Division), the Court upheld the exoneration of a principal whom the Ombudsman had dismissed for oppression. The teacher's June 2002 pay was released in July, after she submitted her daily time record late, and other teachers without clearances had also been left off the June payroll. The Court found no substantial evidence that the principal had singled her out.

The other cases show where the line falls. In a 1995 case, the Civil Service Commission found a principal guilty of oppression for paying two teachers late, facts he never specifically denied, and the Court let his dismissal stand. Refusing, in evident bad faith, to implement two employees' valid promotions was graft in 2011, and a principal demoted for "abuse of authority and vindictiveness" got no back salaries. But a principal who only recommends a teacher's reassignment is not the one to answer for it, and subject loads are for the principal and the regional director to decide. In *Huertas*, a teacher's one-month suspension for gross disrespect stood because he objected to the committee too late and had waived a formal hearing.

The rules are stated as of October 31, 2026.

## Key findings

- **Bad faith is required (*Caberoy*, 2014).** The Court held that "like other grave offenses classified under the Civil Service laws, bad faith must attend the act complained of." A delay in pay that the teacher helped cause, under a requirement applied to other teachers too, was not oppression.
- **Late pay can still be oppression (*Rubenecia*, 1995).** The Civil Service Commission found a principal guilty of oppression for not paying two teachers' differentials and salaries on time; he never specifically denied the facts, so the Commission treated them as admitted. The Court let his dismissal stand.
- **Abuse of authority can cost the post (*Austria*, 1967).** A principal found guilty by the Commissioner of Civil Service of "abuse of authority and vindictiveness", on four teachers' complaint, was demoted to classroom teacher. The Court denied his claim for back salaries.
- **Subject loads are a management decision (*Layug v. Quisumbing*, 1990).** The subjects a teacher handles are "a matter for his principal and the DECS regional director to determine". A teacher may not demand an assignment outside the appointment, and may not be compelled to accept one.
- **The principal who only recommends is not the one to discipline (*Orcino*, 1990).** The Court set aside a Civil Service Commission order to discipline a principal who recommended a teacher's reassignment. If there was any abuse, the Court said, the superintendent who ordered the move should have been charged.
- **Refusing a valid promotion in evident bad faith can be a crime (*Catacutan*, 2011).** An officer-in-charge principal who kept refusing to implement two attested promotions after his superiors had upheld them was convicted under RA 3019, Sec. 3(e).
- **A late objection cost a teacher his case (*Huertas*, 2005), and accusations need proof (*Mallari*, 2004).** A teacher's suspension for gross disrespect toward his principal stood because he objected to the committee too late and had waived a formal hearing. A principal accused of masterminding the shooting of a teacher who had questioned school funds was acquitted.

## Can teachers file an oppression case against their principal?

Yes. Oppression is a ground for disciplinary action in DepEd's rules on administrative cases ([DepEd Order No. 49, s. 2006](https://www.deped.gov.ph/2006/12/12/do-49-s-2006-revised-rules-of-procedure-of-the-department-of-education-in-administrative-cases-amended-by/), Sec. 2(b)). Teachers have also brought oppression complaints against principals before the Civil Service Commission (*Rubenecia*, through its Merit System Protection Board) and the Ombudsman (*Caberoy*). In *Masing*, a separate oppression complaint against a principal also went to the Ombudsman. Which body should hear the charge is covered in [Can the Ombudsman Discipline a Principal?](https://nash.com.ph/blog/ombudsman-deped-jurisdiction-principals).

**What oppression is.** The Court in *Caberoy* said oppression "is also known as grave abuse of authority". It is a misdemeanor of a public officer who, "under color of his office", wrongfully inflicts injury on someone; in the Court's words, it is an act of "cruelty, severity, or excessive use of authority". It must be proved by substantial evidence, which the Court described as the amount of relevant evidence a reasonable mind might accept as adequate to support a conclusion.

**The penalty today.** The [2025 Rules on Administrative Cases in the Civil Service](https://csc.gov.ph/phocadownload/userupload/paio/2025_ORAOHRA_AND_RACCS/2025_RACCS_19_September.pdf) (2025 RACCS), in force since August 4, 2025, list oppression among the grave offenses punished by suspension of six months and one day to one year for the first offense and dismissal for the second (Sec. 63(A)(2)(l)). *Caberoy* applied the 1999 Uniform Rules, which set the same penalties (Sec. 52(A)(14)). The 2025 RACCS lists the offense without defining it, so the definition and the bad-faith requirement still come from the case law. An oppression charge can also support a preventive suspension if the respondent could influence witnesses or tamper with evidence (Sec. 34); see [Preventive Suspension, Appeals and Back Pay for Principals](https://nash.com.ph/blog/principal-preventive-suspension-appeal-back-pay).

**The cases at a glance.**

| Case | What was complained of | Result in the Supreme Court | Why |
|---|---|---|---|
| *Caberoy* (2014) | Principal withheld a teacher's June pay pending clearance and performance appraisal | Exoneration upheld | Pay was released; the teacher's late DTR contributed; no evidence she was singled out; no bad faith shown |
| *Austria* (1967) | Administrative complaint by four teachers (acts not described in the decision) | Demotion stands; no back salaries | Found guilty by the Civil Service Commissioner; a demotion as penalty is not "reinstatement" |
| *Rubenecia* (1995) | Principal did not pay two teachers' salary differentials and pay on time, among other charges | Dismissal stands | CSC findings supported by substantial evidence; he never specifically denied the facts, so they were deemed admitted |
| *Orcino* (1990) | Principal recommended an excess teacher's reassignment | CSC order to discipline her set aside | No factual basis; no reduction in rank, status or salary; she only recommended |
| *Layug v. Quisumbing* (1990) | Principal gave a returning teacher other subjects | Teacher's petition denied | Subjects are for the principal and regional director to decide |
| *Catacutan* (2011) | OIC principal refused to implement two promotions | Conviction under RA 3019, Sec. 3(e) affirmed | Evident bad faith after superiors upheld the appointments; lost pay was undue injury |
| *Huertas* (2005) | Teacher's confrontation with the principal in her office | Teacher's one-month suspension stands | He was estopped from attacking the committee and had waived a formal hearing |
| *Mallari* (2004) | Shooting of a teacher who had questioned school funds | Principal acquitted | Only motive was proved; the rest was hearsay, inadmissible or unauthenticated |

![Timeline of ten decisions, 1967 to 2014. The school head's side prevailed in Layug, Orcino, Mallari, Huertas and Caberoy, and lost in Austria, Rubenecia, St. Michael's, Masing and Catacutan.](https://nash.com.ph/blog/_astro/oppression-outcomes.DU42ITWl_Z1Njq6i.webp)

*Figure 1. Ten Supreme Court decisions on principals and the treatment of teachers, by date and by whether the Court's ruling went the school head's way. Data: ten Supreme Court decisions on oppression and the treatment of teachers (Austria, Layug, Orcino, Rubenecia, St. Michael's, Mallari, Huertas, Masing, Catacutan and Caberoy); outcomes as stated in each decision's dispositive part. Chart: © 2026 Mark Anthony Llego, NASH Reviewer. [Download the full-resolution chart (PNG)](https://nash.com.ph/blog/charts/sc-cases/oppression-outcomes.png) or [its data (CSV)](https://nash.com.ph/blog/charts/sc-cases/oppression-outcomes.csv).*

The count is five and five, but it is not a scorecard. In *Huertas* the principal was the complainant, and *Mallari* is a criminal acquittal on reasonable doubt.

## What oppression requires: bad faith (*Caberoy*, 2014)

**Facts.** Cynthia E. Caberoy was principal of Ramon Avanceña National High School in Arevalo, Iloilo City. A teacher, Angeles O. Tuares, charged her before the Ombudsman with oppression and with violating RA 3019, Sec. 3(e) and (f), for withholding her June 2002 salary. The Ombudsman found that the teacher went unpaid in June because she had not submitted her clearance and her Performance Appraisal Sheet for Teachers, and that she had been singled out. On June 30, 2005 it found Caberoy guilty of oppression only and dismissed her, also citing earlier infractions it attributed to her. The Court of Appeals absolved her on November 21, 2008, and the Ombudsman appealed.

**Issue.** Was there substantial evidence that the principal committed oppression?

**Ruling.** No. The Court denied the Ombudsman's petition and held that the Court of Appeals "did not commit a reversible error in exonerating Caberoy from the charge against her." Its reasons:

- **The teacher was paid.** The vouchers for both June 2002 payroll periods showed her name and signature, and the Ombudsman's own summary showed checks dated July 17 and July 25, 2002 for ₱4,613.80 and ₱4,612.00. Payroll entries are presumed regular, and she offered nothing to the contrary.
- **A delay is not oppression, least of all one the teacher helped cause.** Even if the June pay arrived only in July, the delay "hardly qualifies" as an act of cruelty, severity or excessive use of authority, "especially when she contributed to the cause of the delay": she submitted her June daily time record (Form 48) only on July 11, 2002.
- **No bad faith was shown.** "It must be stressed that like other grave offenses classified under the Civil Service laws, bad faith must attend the act complained of." Bad faith "connotes a dishonest purpose or some moral obliquity and conscious doing of a wrong". "There must be evidence, independent of the fact of such delay, which will lead to the inevitable conclusion that it was for the purpose of singling out Tuares." The Ombudsman's deduction from the dates of vouchers and checks was not that evidence.
- **She was not singled out.** Certifications from the acting bookkeeper showed that other teachers who had not submitted the year-end clearance were also left out of the June payrolls. The Court agreed with the Court of Appeals: "Evidently, [Tuares] was not singled out or discriminated against as insisted by her and respondent Ombudsman."

The ponente was Justice Bienvenido L. Reyes, with no separate opinion. Having found no oppression, the Court did not reach the earlier infractions the Ombudsman cited.

**Why it matters.** The act must be oppressive, and the complainant must show bad faith with evidence, not with inferences from dates. Payroll records, the teacher's own late submission, and proof that other teachers were treated the same way cleared the principal. The ruling rests on that record; it does not hold that a principal may hold back pay whenever a document is missing.

**Later history.** The case applied the 1999 Uniform Rules (the decision's footnote 22). The 2025 RACCS keeps oppression a grave offense with the same penalties, and nothing in it changes the bad-faith requirement.

### When late pay was oppression: *Rubenecia* (1995)

The contrast is [*Rubenecia v. Civil Service Commission*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=37092&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 115942, May 31, 1995 (En Banc), digested in [Dishonesty and Grave Misconduct: Cases on Principals](https://nash.com.ph/blog/principal-dishonesty-grave-misconduct-cases). The Commission found the principal of Catarman National High School guilty of oppression because "He did not give on time the money benefits due" to two teachers: salary differentials for July to December 1987, salaries for May and half of June 1988, proportional vacation pay, and one teacher's June 1987 salary. "Rubenecia did not even attempt to present countervailing evidence." Because he did not specifically deny them, the Commission treated the facts as admitted. With dishonesty, nepotism and a violation of civil service rules (the Commission cleared him of insubordination), the finding led to his dismissal, and the Court found the Commission's findings supported by substantial evidence.

| | *Caberoy* (2014) | *Rubenecia* (1995) |
|---|---|---|
| What was withheld | One teacher's June salary | Two teachers' salary differentials, salaries and vacation pay, over several periods |
| Reason given | No clearance and appraisal sheet; DTR submitted late | None shown in the decision |
| Other teachers treated the same way? | Yes, per the bookkeeper's certifications | Not stated |
| Principal's evidence | Payrolls and vouchers with the teacher's signature | No countervailing evidence; facts deemed admitted |
| Outcome | Exonerated | Dismissal stands (with other offenses) |

## Abuse of authority and vindictiveness (*Austria*, 1967)

[*Austria v. Auditor General*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=20160&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. L-21918, January 24, 1967 (division not stated; ten Justices took part), is the oldest case here. The Court decided only whether the demoted principal could collect back salaries.

**Facts.** Martin B. Austria, a teacher with more than 20 years of permanent service, was designated principal of what is now Olongapo High School, then run under a 1952 Philippine–United States arrangement. Four women teachers filed an administrative complaint against him, and he was suspended on July 13, 1955. On October 13, 1955, the Commissioner of Civil Service found him guilty of "high improper and unbecoming conduct as a school official, abuse of authority and vindictiveness" and ordered him "demoted to the rank of classroom teacher with corresponding salary reduction, transferring him to another station, severely reprimanding him". The Civil Service Board of Appeals affirmed on March 8, 1957. Appointed classroom teacher in the Davao School of Arts and Trades on October 7, 1959, he claimed the principal's salary from July 15, 1955 to that date. The Auditor General denied the claim.

**Issue.** Was his appointment as a classroom teacher a "reinstatement" that entitled him to the salary withheld during his suspension?

**Ruling.** No. The Court, through Justice J.B.L. Reyes, affirmed the Auditor General. "Reinstatement" under the law then in force meant return to the same position, not a demotional appointment made as a penalty: "Petitioner Austria was reinstated not because he was exonerated but because he was found guilty, and his reemployment or reinstatement to a lower position was the penalty for his guilt." He was not punished twice, because the ground for his suspension existed when he committed the acts complained of. His proper remedy had been an appeal to the President.

**Why it matters.** A principal found guilty of abusing authority over teachers can lose the principalship itself, with no back pay for the suspension. The decision does not describe the acts behind the finding, so it cannot tell us which acts are vindictive.

**Later history.** Back pay is now governed by Book V of the 1987 Administrative Code and the 2025 RACCS; see [Preventive Suspension, Appeals and Back Pay for Principals](https://nash.com.ph/blog/principal-preventive-suspension-appeal-back-pay).

## Loads, assignments and details (*Layug v. Quisumbing*, 1990)

[*Layug v. Quisumbing*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=33026&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 82272, February 7, 1990 (First Division), is the Court's clearest statement on who decides what a teacher teaches. The principal, Ramon Presto, was a respondent and prevailed.

**Facts.** Ponciano M. Layug had taught English and Biology at Davao del Sur National High School in Digos since 1971. In 1986 he charged his principal with harassment and oppression. In August 1987, after students, teachers and parents demonstrated against him, the principal filed countercharges of dishonesty, incompetence, insubordination and being notoriously undesirable, and the teacher was preventively suspended. When the suspension was lifted on October 13, 1988, his classes had gone to other teachers. The principal assigned him YDT/CAT subjects, explaining in a memorandum that nothing else was free and that changing teachers mid-term would not be good for the students. He refused. On the principal's recommendation, the Regional Director then assigned him temporarily to the guidance office, with the same status and pay, since he was a psychology major. He refused that too, and reported only on January 5, 1989, after a warning that his separation would be recommended.

**Issues.** Must he be restored to his English and Biology classes? Is he owed salary for his suspension and for the months he refused his assignments?

**Ruling.** No on both. The Court, through Justice Griño-Aquino, held:

- **Reinstatement is to the position in the appointment, not to particular subjects.** Citing the Education Act of 1982 (B.P. Blg. 232, Sec. 11), the Court said: "Evidently, a teacher may not be compelled to accept, and neither may he demand to be given, an assignment not specified in his appointment."
- **Subjects are for the principal and the regional director.** "The selection of the subjects which petitioner may teach is a matter for his principal and the DECS regional director to determine based on his qualifications and the prevailing conditions in the school." With his classes reassigned and a mid-year change bad for students, the assignments stood, and his contempt motion was baseless.
- **No back salaries.** His suspension was authorized, he had not been absolved, and it ran past 90 days because of his own postponements and absences. For the months he refused his assignments, "As you work, so shall you earn": he was paid only from January 5, 1989.

**Why it matters.** Assigning subjects is for the principal and the regional director, decided on the teacher's qualifications and the school's conditions, and a principal who explains the decision in writing is on firm ground. The case does not let a principal use loads to punish; its reasoning rests on the students' interest and an assignment within the appointment. The decision does not say how the complaint and countercharges ended.

**Later history.** Teaching loads are now set by [DepEd Order No. 005, s. 2024](https://www.deped.gov.ph/2024/04/29/april-29-2024-do-005-s-2024-rationalization-of-teachers-workload-in-public-schools-and-payment-of-teaching-overload/) and RA 4670's six-hour limit; see [How School Heads Plan Teaching Loads Under DO 5](https://nash.com.ph/blog/school-head-teacher-loading-workload-toolkit). The 90-day rule came from P.D. 807, Sec. 42; today's is in the 2025 RACCS.

## Reassigning a teacher: the principal only recommends (*Orcino*, 1990)

[*Orcino v. Civil Service Commission*](https://lawphil.net/judjuris/juri1990/oct1990/gr_92869_1990.html), G.R. No. 92869, October 18, 1990 (En Banc), protects a principal who recommends a personnel action in good faith. It was unanimous; Justice Gutierrez, Jr. wrote it.

**Facts.** In school year 1984–1985, enrollment at Malvar Elementary School in Manila fell and intermediate classes dropped from eleven to ten, leaving one excess teacher, while Grade IV had a vacancy. Under the division's 1982 guidelines, all 58 teachers were evaluated, and Rufina B. Moti ranked last on performance, length of service and relative fitness combined. She refused a Grade IV class and insisted on an intermediate one. Principal Zenaida Orcino recommended her reassignment, and the Division Superintendent moved her to another school. The Ministry of Education and the CSC Merit Systems Board upheld the move, but the Civil Service Commission reversed: it ordered the teacher restored as a Grade VI teacher and ordered disciplinary action against the principal.

There was conflict behind the move. The teacher's Tanodbayan complaint against the principal over contributions from teachers was dismissed in 1985; some teachers said the contributions were voluntary and the principal had nothing to do with them. The principal's complaint of non-cooperation and defiance of school rules ended in a fine of five days' salary for the teacher. The teacher also accused the principal of coercing her and telling her to stop attending teachers' association meetings. The Court noted that "in all these charges and counter charges", the principal was sustained at every level except the Commission.

**Issue.** Were the Commission's findings supported, and could the principal be disciplined?

**Ruling.** The Court granted the principal's petition, set aside the Commission's resolutions, dismissed the teacher's complaint and made its restraining order permanent.

- **No factual basis.** The teacher's appointment named no station, and a move from Grade VI to Grade IV "involves no reduction in rank, status, or salary". "Faced with an excess of teachers it was the duty of the petitioner as school principal to recommend a solution to the problem." And "A cooperative attitude and a certain degree of flexibility are required of all who profess to be educators."
- **The principal only recommended.** Even assuming the Commission was right, the Court saw no reason why the principal, "a purely recommendatory authority", should be penalized while the officials who ordered and upheld the transfer went free: "If there was any abuse of authority or arbitrariness, the Division Superintendent of City Schools who makes all the appointments, transfers, and other personnel action should have been charged and not the Principal."
- **No ill motive was shown.** The Court accepted that "there is bad blood between the petitioner and the private respondent", but held: "There is no showing of arbitrary or ill-motivated conduct in this case." School administrators, it said, "deserve all the assistance they can get in maintaining discipline in their schools", except when there is a strong showing of willful and arbitrary conduct.

The Court relied on *Brillantes v. Guevarra* and *Sta. Maria v. Lopez*.

**Why it matters.** A principal who recommends a reassignment on documented criteria, such as an excess-teacher ranking, is not answerable for the decision of the official who orders it. The case does not make every recommendation safe. A recommendation can itself be an offense when the law says so, as with recommending a relative for a non-teaching post (*Rubenecia*). And the "recommendatory" point was an alternative ground: the main holding was that the Commission's findings had no basis in the record.

**Later history.** Today a teacher's reassignment is governed by the teachers' own laws, with the 2025 Omnibus Rules on Appointments and Other Human Resource Actions applied suppletorily ([CSC MC No. 08, s. 2025](https://csc.gov.ph/phocadownload/userupload/irmo/mc/2025/MC%20No.%2008%20s.%202025.pdf), Sec. 13(a), item 5). For principals, see [Can a Principal Be Reassigned to Another School?](https://nash.com.ph/blog/principal-reassignment-transfer-oic-tenure).

## Refusing promotions in bad faith, and RA 4670's penal clause

**Refusing a valid promotion in bad faith (*Catacutan*, 2011).** In [*Catacutan v. People*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=56908&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 175991, August 31, 2011 (First Division), the officer-in-charge principal of the Surigao del Norte School of Arts and Trades refused from June to November 1997 to implement the CSC-attested promotions of two employees, an instructor and an education program specialist, despite written orders from CHED and the CSC. The Court affirmed his conviction under [RA 3019](https://lawphil.net/statutes/repacts/ra1960/ra_3019_1960.html), Sec. 3(e): six years and one month in prison, perpetual disqualification, and ₱50,000 in moral damages to each complainant. There was evident bad faith once "the higher authorities have already sustained the validity of the subject appointments and have ordered him to proceed with the implementation". By his account, the administrative case had gone his way. The two complainants had charged him before the Ombudsman with grave abuse of authority and disrespect of lawful orders, and, as the decision records his argument, the Court of Appeals "denied the administrative case filed against him" and found that his refusal "falls short of malice or wrongful intent". The trial court excluded that decision, and the Court agreed: it was not in the record, and findings in an administrative case do not bind a criminal court. The full digest is in [Promotion Protests and Nepotism: Cases on Principals](https://nash.com.ph/blog/principal-promotion-protest-nepotism-cases).

**RA 4670, Sec. 32 (*People v. Dacuycuy*, 1989).** The Magna Carta for Public School Teachers has its own penal clause. [RA 4670](https://lawphil.net/statutes/repacts/ra1966/ra_4670_1966.html), Sec. 32, punishes "A person who shall willfully interfere with, restrain or coerce any teacher in the exercise of his rights guaranteed by this Act". Those rights include the freedom to organize: Sec. 28 makes it unlawful to prejudice a teacher for membership in an organization or for taking part in its activities (outside school hours, or within them with the school authorities' consent).

- **Facts.** In [*People v. Dacuycuy*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=31551&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. L-45127, May 5, 1989 (En Banc), three "public school officials of Leyte" were charged in 1975 with violating RA 4670; the decision does not say what they did or which posts they held. They argued that Sec. 32 was void because it set no term for the prison penalty.
- **Ruling.** The Court, through Justice Regalado, declared the imprisonment penalty unconstitutional: with no minimum or maximum, it left the term to the courts, an undue delegation of legislative power. The fine of ₱100 to ₱1,000 remains, and the case was remanded to the municipal trial court for trial.
- **Why it matters.** Interfering with a teacher's Magna Carta rights remains a crime, punishable by a fine. Sec. 32 also says that if the offender is a public official, "the court shall order his dismissal from the Government service". *Dacuycuy* did not discuss that paragraph.
- **Currency.** RA 4670 has not been amended. [DepEd Memorandum No. 057, s. 2026](https://www.deped.gov.ph/2026/09/22/september-21-2026-dm-057-s-2026-creation-of-a-national-technical-working-group-ntwg-for-the-development-of-roadmap-for-the-magna-carta-for-public-school-teachers-republic-act-no-4670/) created a working group to propose amendments, and bills such as House Bill No. 8759 have been filed, but the law is unchanged as of October 31, 2026.

## When the principal files the complaint (*Huertas*, 2005)

[*Huertas v. Gonzalez*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=48602&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 152443, February 14, 2005 (Second Division), is a case in which the principal was the complainant.

**Facts.** Angelito M. Huertas, a teacher at Bacood Elementary School in Manila, had just been re-elected faculty club president and was running a signature campaign. Told that the principal, Dr. Carolina C. Dizon, was keeping teachers from signing, he went to her office. As the decision recounts it, he "angrily demanded" to know why, and warned her, in the Court's translation, "If you don't stop, I will sue you." She charged him with grave misconduct, disrespect of authority and violation of the Magna Carta. A committee from the division's Legal Affairs and Complaints Service, which the decision calls a grievance committee, heard the case on affidavits with his agreement and recommended a six-month suspension. On October 16, 1996 the Regional Director dropped the grave misconduct charge for lack of substantial evidence, found him guilty of gross disrespect, and suspended him for one month without pay. After DECS Secretaries reversed one another, twice on the principal's motions for reconsideration, the Regional Director's ruling was restored, and the Court of Appeals in the end dismissed the teacher's petition.

**Issues.** Was the committee void because it was not composed as RA 4670, Sec. 9 requires? Could the principal, as complainant, ask for reconsideration?

**Ruling.** The Court, through Justice Callejo, Sr., denied the teacher's petition.

- **The committee was wrong, but he was estopped.** The committee came from the division's legal office, not the Sec. 9 composition, so "the Committee that was tasked to conduct the formal investigation was not the competent tribunal required by the law." But he never objected before the committee, the Regional Director or the Secretaries, and raised the point first in the Court of Appeals. "Verily then, the petitioner is estopped from assailing the competence of the committee." He had also agreed to submit the case on affidavits: "In fine, the petitioner waived his right to a formal investigation."
- **The principal could move for reconsideration.** Secretary Gloria's resolution had not exonerated the teacher; it "merely nullified the proceedings before the committee". So the principal's motion was not an appeal from an exoneration. The Court also noted that it had already abandoned the old doctrine barring appeals by anyone other than the respondent.

**Why it matters.** A principal may file a complaint against a teacher. But the Supreme Court did not re-examine the evidence of disrespect; it decided the case on estoppel, waiver and the principal's right to seek reconsideration. A teacher who objects to a committee from the start can get the opposite result; see [Can the Ombudsman Discipline a Principal?](https://nash.com.ph/blog/ombudsman-deped-jurisdiction-principals).

**Later history.** The procedure in *Huertas* would not be followed today. DepEd's rules now say that "A Grievance Committee is not allowed to hear and decide administrative disciplinary cases" (DO 49, s. 2006, Sec. 2). When the respondent is a teacher, the formal investigating committee follows the RA 4670 composition (Sec. 21(a)). Under the 2025 RACCS, discourtesy in the course of official duties is a less grave offense (Sec. 63(B)(1)).

## Grievances are not administrative cases (DO 35, s. 2004; DO 49, s. 2006)

Most friction between a principal and a teacher never becomes a case. [DepEd Order No. 35, s. 2004](https://www.deped.gov.ph/2004/06/03/do-35-s-2004-revision-of-the-grievance-machineries-of-the-department-of-education/) sends work-related complaints through the grievance machinery, including "unreasonable withholding of salaries", detail and transfer issues, and poor interpersonal relationships. Its list also includes protests on appointments, but since 2010 a protest "shall no longer be acted upon through the grievance machinery" ([DepEd Order No. 32, s. 2016](https://www.deped.gov.ph/2016/05/26/do-32-s-2016-addendum-to-deped-order-no-3-s-2016-hiring-guidelines-for-senior-high-school-shs-teaching-positions-effective-school-year-sy-2016-2017/), applying CSC Memorandum Circular No. 4, s. 2010); see [Promotion Protests and Nepotism](https://nash.com.ph/blog/principal-promotion-protest-nepotism-cases). DO 35 excludes disciplinary cases, RA 7877 sexual-harassment cases, and union-related issues and concerns. A grievance against the immediate supervisor may go to the next higher supervisor, and officials who refuse to act on a grievance "shall be liable for neglect of duty". The [human resource management guide](https://nash.com.ph/blog/school-head-human-resource-management) explains the steps; The steps and time limits are in [DepEd Grievance Machinery: Steps and Time Limits](https://nash.com.ph/blog/deped-grievance-machinery-do-35), and the dividing line in [Grievance or Administrative Case? Where to File](https://nash.com.ph/blog/grievance-or-administrative-case-deped).

If the teacher is charging the principal with an offense such as oppression, it is a disciplinary case for the disciplining authority, and a grievance committee may not decide it (DO 49, s. 2006, Sec. 2).

## Conflicts that escalate (*Mallari*, 2004)

[*Mallari v. People*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=46435&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 153911, December 10, 2004 (Third Division), ended in the principal's acquittal. It shows only how far a dispute over school funds went.

**Facts.** Melanio Mallari was principal of Bustamante High School in Davao City. A teacher and guidance counselor there testified that in March 1989 she had handed him a letter questioning, among other things, his accounting for fees collected from students. On June 29, 1989 a man shot and wounded her. The gunman and his brother, in statements to the police, named the principal as the one who had hired them, and later repudiated those statements. The trial court convicted all three of frustrated murder; the Court of Appeals changed the crime to attempted murder.

**Issue.** Was the circumstantial evidence enough to convict the principal?

**Ruling.** No. The Court, through Justice Panganiban, reversed the conviction as to the principal and acquitted him on reasonable doubt. Of the circumstances the lower courts relied on, only motive, drawn from the teacher's letter, could be given weight. The rest rested on hearsay police testimony, on co-accused statements that are inadmissible against him because the co-accused did not testify against him, and on a letter no one authenticated. With nothing more, "his constitutional right to be presumed innocent must prevail."

**Why it matters.** The Court decided a criminal case only and addressed no administrative case. The practical lesson is to answer questions about school funds openly and on the record; see [Can a Principal Be Jailed Over School Funds?](https://nash.com.ph/blog/principal-malversation-graft-school-funds).

## Private schools and Ombudsman cases

- **Private schools.** In [*St. Michael's Institute v. Santos*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=44022&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 145280, December 4, 2001 (Second Division), a private school dismissed three teachers, all union officers, for what the Court called their "absence for only one day of classes for attending a public rally and denouncing the school authority". A committee the principal set up found they had led the rally, which two of them denied. The Court agreed that dismissal "appears to be too harsh a penalty", noting that the teachers appeared to have been singled out as union officers. It affirmed the Court of Appeals: two teachers were reinstated with back wages, and the third received separation benefits and back wages to December 11, 1998, when she turned 65. Private-school cases turn on the Labor Code, not on the civil service offense of oppression; see [Can a Private School Remove Its Principal?](https://nash.com.ph/blog/private-school-principal-dismissal-cases).
- **The Ombudsman.** In [*Office of the Ombudsman v. Masing*](https://lawphil.net/judjuris/juri2008/jan2008/gr_165416_2008.html), G.R. Nos. 165416, 165584 and 165731, January 22, 2008 (First Division; Puno, C.J.), the Court reinstated the Ombudsman's decisions against a former principal. In the separate oppression case, the Ombudsman had found her "guilty as charged" of oppression and other offenses and suspended her for six months. The Court of Appeals set that aside, and the Supreme Court reinstated it. The Court ruled on the Ombudsman's power and did not review the evidence of oppression; see [Can the Ombudsman Discipline a Principal?](https://nash.com.ph/blog/ombudsman-deped-jurisdiction-principals).

## What this means for school heads

Each practice below leaves a record you can show if a complaint is filed.

**On pay and benefits**

- **Put any pay-related requirement in writing and apply it to everyone.** In *Caberoy*, the bookkeeper's certifications proved that other teachers were treated the same way.
- **Release pay as soon as the requirement is met, and keep the dates.** The payroll vouchers with the teacher's signature were the Court's first reason in *Caberoy*.
- **Do not sit on differentials, vacation pay or other benefits.** In *Rubenecia*, money owed to two teachers and paid late became an oppression finding. Unreasonable withholding of salaries is also a grievance under DO 35, s. 2004.

**On loads, assignments and reassignments**

- **Base subject and section assignments on qualifications and the school's needs, and explain them in a memorandum** (*Layug*). Follow DO 005, s. 2024 on loads.
- **Keep assignments within the teacher's appointment** (*Layug*, quoting B.P. Blg. 232, Sec. 11).
- **Recommend reassignments on documented criteria, such as an excess-teacher ranking, and leave the decision to the official who makes it** (*Orcino*). Never recommend a relative within the prohibited degree for a non-teaching post (*Rubenecia*).

**On promotions and organizations**

- **Implement attested appointments even when you object, and raise your objection through channels** (*Catacutan*).
- **Do not interfere with teachers' organizations.** Pressuring a teacher not to join an organization, or penalizing a teacher for taking part in its activities, can fall under RA 4670, Secs. 28 and 32.

**When there is conflict**

- **Keep personal conflict out of personnel actions.** When a teacher has a complaint pending against you, consider asking the Schools Division Office to review actions that affect that teacher. This is good practice, not a rule from the cases.
- **Hear grievances promptly and in private.** Officials who refuse to act on a grievance are liable for neglect of duty under DO 35.
- **If a teacher is disrespectful, file a sworn complaint with the disciplining authority, as the principal in *Huertas* did.** The proper committee, not a grievance committee, hears it (DO 49, Secs. 2, 4 and 21).
- **If you are charged, answer with evidence.** Payroll records and the bookkeeper's certifications helped clear the principal in *Caberoy*; in *Rubenecia*, facts never specifically denied were deemed admitted. Consult your Schools Division Office's legal unit.

These practices map to PPSSH strands 2.4, management of staff ([Domain 2](https://nash.com.ph/blog/ppssh-domain-2-managing-school-operations)); 4.7, general welfare of human resources ([Domain 4](https://nash.com.ph/blog/ppssh-domain-4-developing-self-and-others)); and 5.1, management of diverse relationships ([Domain 5](https://nash.com.ph/blog/ppssh-domain-5-building-connections)). On recommending staff, see [RA 9155 Duties of DepEd School Heads](https://nash.com.ph/blog/ra-9155-school-head-duties).

## How the NASH may test this

The two items below are original practice items, scored 3 (Relational), 2 (Multistructural), 1 (Unistructural) or 0 (Prestructural). An option that breaks a rule scores 0.

### Question 1

*Indicator 2.4.1, Management of staff. Career Stage 1, Conceptual, Moderate.*

A principal applies a written school rule: teachers who have not submitted their year-end clearance are left off the June payroll until they do. Five teachers are left off. One of them submits her daily time record in July, is paid in July, and charges the principal with oppression, saying she was singled out. Which statement best reflects the Supreme Court's rulings on oppression?

- **A.** The principal is liable, because any delay in releasing a teacher's salary is oppression, whatever the reason for it.
- **B.** The principal is not liable, because the teacher was eventually paid.
- **C.** The principal is not liable, because a delay that the teacher helped cause is not an act of cruelty, severity or excessive use of authority.
- **D.** The complaint needs substantial evidence of bad faith, such as proof that she was singled out. A rule applied to every teacher without clearance, a delay she helped cause, and pay released once she complied do not show it, though unexplained or selective withholding could.

**Answer and explanation**

**Best answer: D.** Points: A = 0, B = 1, C = 2, D = 3.

- **A (0 points, Prestructural).** This is the misconception the Court rejected: a delay alone is not oppression.
- **B (1 point, Unistructural).** Payment mattered in *Caberoy*, but late payment can still be oppression, as in *Rubenecia*.
- **C (2 points, Multistructural).** Right about the delay the teacher helped cause, but it leaves out bad faith and the evidence on singling out.
- **D (3 points, Relational).** It states the standard, applies it to the facts, and marks where the line would fall the other way.

**Why.** In *Office of the Ombudsman v. Caberoy* (2014), the Court held that "bad faith must attend the act complained of" and required evidence, beyond the delay itself, that the teacher was singled out. Other teachers without clearances had also been left off the payroll, and the teacher's late daily time record contributed to the delay. In *Rubenecia v. CSC* (1995), by contrast, the Commission's oppression finding rested on pay given late, facts the principal never specifically denied.

*Indicator 2.4.1: Demonstrate knowledge and understanding of laws, policies, guidelines and issuances on managing school staff.*

*Sources: Office of the Ombudsman v. Caberoy, G.R. No. 188066, October 22, 2014; Rubenecia v. Civil Service Commission, G.R. No. 115942, May 31, 1995; DepEd Order No. 35, s. 2004, Part V.*

### Question 2

*Indicator 2.4.2, Management of staff. Career Stage 2, Situational, Difficult.*

You are the principal of a national high school. In October, a Biology teacher returns to work after her preventive suspension is lifted. Her two Biology classes were given to another teacher in June. She has a complaint pending against you, and she demands her old classes back. The only sections without a teacher are two Earth Science classes, which she is qualified to teach and which fall within her appointment as a secondary school teacher. What is the most appropriate action?

- **A.** Give her no classes until her administrative case is decided, since a teacher with a pending case should not handle learners.
- **B.** Return her Biology classes at once and give the Earth Science sections to the teacher who took them, so that no one can say you retaliated.
- **C.** Assign her the two Earth Science sections and tell her that the decision is final.
- **D.** Assign her the Earth Science sections and explain in a memorandum that her Biology classes stay with their current teacher to spare learners a mid-year change. Apply the loading rules you use for all teachers, file a copy, and tell her she may raise the matter through the grievance machinery, which goes to your supervisor when the grievance is against you.

**Answer and explanation**

**Best answer: D.** Points: A = 0, B = 1, C = 2, D = 3.

- **A (0 points, Prestructural).** Her suspension has been lifted; keeping her idle extends it without authority and looks like retaliation.
- **B (1 point, Unistructural).** It avoids the look of retaliation, but she has no right to particular subjects, and a mid-year switch hurts learners.
- **C (2 points, Multistructural).** The assignment is right, but with no written reasons, no common rule and no channel for her concern, it invites a complaint.
- **D (3 points, Relational).** It makes the lawful assignment, records the learners' interest behind it, applies one rule to everyone, and gives her a route that bypasses you.

**Why.** In *Layug v. Quisumbing* (1990), on similar facts, the Court held that subjects are "a matter for his principal and the DECS regional director to determine based on his qualifications and the prevailing conditions in the school", and that a teacher "may not be compelled to accept, and neither may he demand to be given, an assignment not specified in his appointment." The principal there explained in a memorandum that changing teachers mid-term would hurt the students. A grievance against the immediate supervisor may go to the next higher supervisor (DO 35, s. 2004, Part VI). Loads follow DO 005, s. 2024.

*Indicator 2.4.2: Manage staffing such as teaching load distribution and grade level and subject area assignment in adherence to laws, policies, guidelines and issuances based on the needs of the school.*

*Sources: Layug v. Quisumbing, G.R. No. 82272, February 7, 1990; DepEd Order No. 35, s. 2004, Part VI; DepEd Order No. 005, s. 2024.*

Nothing in this guide reproduces or predicts examination content.

## Frequently asked questions

### Can a teacher file an oppression case against a principal?

Yes. Oppression is a ground for discipline under DO 49, s. 2006, Sec. 2(b), and a grave offense under the 2025 RACCS, punished by suspension of six months and one day to one year for a first offense. The teacher must prove it by substantial evidence, including bad faith (*Office of the Ombudsman v. Caberoy*, 2014). Where to file is explained in [Can the Ombudsman Discipline a Principal?](https://nash.com.ph/blog/ombudsman-deped-jurisdiction-principals)

### Is it oppression to hold a teacher's salary until clearance is submitted?

Not by itself. In *Caberoy* (2014) the Court found no oppression where the teacher's June pay was released in July, her own daily time record was late, and other teachers without clearance were treated the same way. But in *Rubenecia* (1995) the Commission found oppression in salary differentials and salaries paid late, facts the principal never specifically denied, and the Court let the finding stand. Unreasonable withholding of salaries is also a grievance under DO 35, s. 2004.

### Can a principal be disciplined for recommending a teacher's transfer?

Not for a good-faith recommendation on proper grounds. In *Orcino v. CSC* (1990) the Court set aside an order to discipline a principal who recommended an excess teacher's reassignment, calling her "a purely recommendatory authority". If there was any abuse, the superintendent who ordered the move should have been charged. A recommendation the law itself forbids, such as recommending a relative for a non-teaching post, is different (*Rubenecia*, 1995).

### Can a teacher refuse a subject the principal assigns?

Not one within the appointment. In *Layug v. Quisumbing* (1990) the Court held that subjects are for the principal and the regional director to decide, and that a teacher may neither demand nor be compelled to accept an assignment outside the appointment. The teacher there, who refused his assignments, was paid only from the day he reported.

### Should a teacher's complaint against the principal go to the grievance committee?

It depends on the complaint. Work-related dissatisfaction, such as a load, a delayed salary or a strained relationship, goes through the grievance machinery of DO 35, s. 2004, which excludes union-related issues, and the teacher may go past a supervisor who is the object of the grievance. A charge of an offense such as oppression is a disciplinary case, which a grievance committee "is not allowed to hear and decide" (DO 49, s. 2006, Sec. 2). *Huertas* (2005) arose before that rule.

## Download the data

- [oppression-outcomes.csv](https://nash.com.ph/blog/charts/sc-cases/oppression-outcomes.csv): the ten Supreme Court decisions in Figure 1, with G.R. number, date, court, kind of case, whether the ruling went the school head's way, and what the Court did.

The CSVs and charts may be reused only with written permission: email [support@nash.com.ph](mailto:support@nash.com.ph). The decisions themselves are public records of the Supreme Court, which you can cite directly.

## Sources

**Supreme Court decisions**

- [*Office of the Ombudsman v. Caberoy*](https://lawphil.net/judjuris/juri2014/oct2014/gr_188066_2014.html), G.R. No. 188066, October 22, 2014 (Third Division; Reyes, J.).
- [*Austria v. Auditor General*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=20160&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. L-21918, January 24, 1967 (division not stated; J.B.L. Reyes, J.).
- [*Layug v. Quisumbing*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=33026&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 82272, February 7, 1990 (First Division; Griño-Aquino, J.).
- [*Orcino v. Civil Service Commission*](https://lawphil.net/judjuris/juri1990/oct1990/gr_92869_1990.html), G.R. No. 92869, October 18, 1990 (En Banc; Gutierrez, Jr., J.).
- [*Rubenecia v. Civil Service Commission*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=37092&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 115942, May 31, 1995 (En Banc; Feliciano, J.).
- [*Catacutan v. People*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=56908&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 175991, August 31, 2011 (First Division; Del Castillo, J.).
- [*People v. Dacuycuy*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=31551&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. L-45127, May 5, 1989 (En Banc; Regalado, J.).
- [*Huertas v. Gonzalez*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=48602&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 152443, February 14, 2005 (Second Division; Callejo, Sr., J.).
- [*Mallari v. People*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=46435&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 153911, December 10, 2004 (Third Division; Panganiban, J.).
- [*St. Michael's Institute v. Santos*](https://elibrary.judiciary.gov.ph/assets/dtSearch/dtSearch_system_files/dtisapi6.dll?cmd=getdoc&DocId=44022&Index=%2a4aeb4dbdcceeda9b59b85ae3fb22cec0), G.R. No. 145280, December 4, 2001 (Second Division; De Leon, Jr., J.).
- [*Office of the Ombudsman v. Masing*](https://lawphil.net/judjuris/juri2008/jan2008/gr_165416_2008.html), G.R. Nos. 165416, 165584 and 165731, January 22, 2008 (First Division; Puno, C.J.).

**Laws and rules**

- [Republic Act No. 4670](https://lawphil.net/statutes/repacts/ra1966/ra_4670_1966.html), Magna Carta for Public School Teachers, June 18, 1966, Secs. 9, 13, 27, 28 and 32.
- [Republic Act No. 3019](https://lawphil.net/statutes/repacts/ra1960/ra_3019_1960.html), Anti-Graft and Corrupt Practices Act, Sec. 3(e).
- [Batas Pambansa Blg. 232](https://lawphil.net/statutes/bataspam/bp1982/bp_232_1982.html), Education Act of 1982, Sec. 11, as quoted in *Layug*.
- [2025 Rules on Administrative Cases in the Civil Service](https://csc.gov.ph/phocadownload/userupload/paio/2025_ORAOHRA_AND_RACCS/2025_RACCS_19_September.pdf), CSC Resolution No. 2500357, April 30, 2025, effective August 4, 2025, Secs. 34, 63(A)(2)(l) and 63(B)(1).
- [2025 Omnibus Rules on Appointments and Other Human Resource Actions](https://csc.gov.ph/phocadownload/userupload/irmo/mc/2025/MC%20No.%2008%20s.%202025.pdf), CSC MC No. 08, s. 2025, Sec. 13(a), item 5.
- [DepEd Order No. 35, s. 2004](https://www.deped.gov.ph/2004/06/03/do-35-s-2004-revision-of-the-grievance-machineries-of-the-department-of-education/), Revision of the Grievance Machinery of the Department of Education, June 3, 2004, Parts V, VI and VII.
- [DepEd Order No. 32, s. 2016](https://www.deped.gov.ph/2016/05/26/do-32-s-2016-addendum-to-deped-order-no-3-s-2016-hiring-guidelines-for-senior-high-school-shs-teaching-positions-effective-school-year-sy-2016-2017/), Addendum to DepEd Order No. 3, s. 2016, Part I (Protest Procedures), applying CSC Memorandum Circular No. 4, s. 2010.
- [DepEd Order No. 49, s. 2006](https://www.deped.gov.ph/2006/12/12/do-49-s-2006-revised-rules-of-procedure-of-the-department-of-education-in-administrative-cases-amended-by/), Revised Rules of Procedure of the Department of Education in Administrative Cases, December 12, 2006, Secs. 2, 4 and 21.
- [DepEd Order No. 005, s. 2024](https://www.deped.gov.ph/2024/04/29/april-29-2024-do-005-s-2024-rationalization-of-teachers-workload-in-public-schools-and-payment-of-teaching-overload/), Rationalization of Teachers' Workload in Public Schools and Payment of Teaching Overload, April 29, 2024.
- [DepEd Memorandum No. 057, s. 2026](https://www.deped.gov.ph/2026/09/22/september-21-2026-dm-057-s-2026-creation-of-a-national-technical-working-group-ntwg-for-the-development-of-roadmap-for-the-magna-carta-for-public-school-teachers-republic-act-no-4670/), September 21, 2026.

*This guide explains Supreme Court decisions for study and professional awareness. It is not legal advice; for a specific case, consult a lawyer or your Schools Division Office's legal unit.*

## The Supreme Court cases series

- [Supreme Court Cases on School Heads: A Guide for Principals](https://nash.com.ph/blog/supreme-court-cases-school-heads)
- [Can the Ombudsman Discipline a Principal? RA 4670 Cases](https://nash.com.ph/blog/ombudsman-deped-jurisdiction-principals)
- [Can a Principal Be Reassigned to Another School?](https://nash.com.ph/blog/principal-reassignment-transfer-oic-tenure)
- [Promotion Protests and Nepotism: Cases on Principals](https://nash.com.ph/blog/principal-promotion-protest-nepotism-cases)
- [Unauthorized School Fees: What Happens to the Principal?](https://nash.com.ph/blog/unauthorized-school-fees-principal-cases)
- [Can a Principal Be Jailed Over School Funds?](https://nash.com.ph/blog/principal-malversation-graft-school-funds)
- [Dishonesty and Grave Misconduct: Cases on Principals](https://nash.com.ph/blog/principal-dishonesty-grave-misconduct-cases)
- Oppression Cases: How Principals Must Treat Teachers (this post)
- [Harassment, Child Abuse and Hazing: Cases on School Heads](https://nash.com.ph/blog/school-head-harassment-child-abuse-hazing-cases)
- [Is a Principal Liable When a Pupil Is Injured?](https://nash.com.ph/blog/principal-liability-pupil-injury)
- [Can a Private School Remove Its Principal?](https://nash.com.ph/blog/private-school-principal-dismissal-cases)
- [Preventive Suspension, Appeals and Back Pay for Principals](https://nash.com.ph/blog/principal-preventive-suspension-appeal-back-pay)

*Written by Mark Anthony Llego for NASH Reviewer. Sources: Supreme Court decisions in Caberoy, Austria, Layug, Orcino, Rubenecia, Catacutan, Dacuycuy, Huertas, Mallari, St. Michael's and Masing; RA 4670; RA 3019; the 2025 RACCS; DepEd Orders No. 35, s. 2004, No. 49, s. 2006 and No. 005, s. 2024. Charts may be reused only with written permission from support@nash.com.ph.*

---

© 2026 Mark Anthony Llego, NASH Reviewer. All rights reserved. You may quote up to 100 words from this article with the author's name, its title and a link. In research, cite it as: Llego, M. A. (2026, October 31). *Oppression Cases: How Principals Must Treat Teachers*. NASH Reviewer. https://nash.com.ph/blog/principal-oppression-teachers-cases. Any other reuse of the article, its charts or its data needs written permission: email support@nash.com.ph. Terms of Service: https://nash.com.ph/terms#website-content-and-data