I. Introduction

In Philippine public schools, the hierarchical structure—where principals, supervisors, district supervisors, and other superiors exercise significant authority over teachers and non-teaching personnel—creates an environment where abuse of power can manifest as workplace bullying and verbal harassment. These acts range from repeated public humiliation, derogatory name-calling, shouting, threats of non-promotion or undesirable assignments, to sustained patterns of belittlement that undermine the victim's professional dignity and mental health.

While the Philippines has no specific statute entitled "Anti-Workplace Bullying Act" applicable to all workplaces (proposed bills remain pending in Congress as of 2025), public school personnel enjoy multiple layers of protection under constitutional guarantees, the Civil Service rules, the Revised Penal Code, the Civil Code, Republic Act No. 6713, Republic Act No. 7877, Republic Act No. 11313 (Safe Spaces Act), and DepEd-issued policies and orders. Victims are therefore not without remedy; in fact, public school superiors who engage in such conduct face severe administrative, civil, and criminal sanctions, including dismissal from service.

This article comprehensively discusses the nature of the problem, the applicable legal frameworks, available remedies, procedural requirements, evidentiary standards, and relevant jurisprudence.

II. Defining Workplace Bullying and Verbal Harassment in the Public School Context

Workplace bullying is repeated, unreasonable behavior directed towards an employee or group of employees that creates a risk to health and safety. Verbal harassment is a subset consisting of oral or written words intended to humiliate, intimidate, degrade, or offend.

Common manifestations in Philippine public schools include:

Public shaming during flag ceremonies, faculty meetings, or in front of pupils and parents
Calling teachers "bobo," "walang kwenta," "tanga," or other derogatory terms
Shouting "Putang ina mo!" or similar profane language
Threatening non-renewal of designation, delay of salary, or undesirable transfers
Sustained sarcastic criticism of teaching performance in front of colleagues
Spreading malicious rumors or labeling a teacher as "pasaway" or "rebelde" without basis

When committed by a superior, these acts constitute abuse of authority and oppression.

III. Constitutional and Statutory Protections

1987 Constitution
- Article II, Section 11 – The State values the dignity of every human person
- Article XIII, Section 3 – Full protection to labor, promotion of equal work opportunities, and humane conditions of work
- Article IX-B, Section 2(3) – Security of tenure of civil servants
Republic Act No. 4670 (Magna Carta for Public School Teachers)
- Section 10 – No discrimination or harassment
- Section 23 – Safeguards in disciplinary procedures
Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees)
- Section 4(c) – Justness and sincerity; professionalism; responsiveness to the public
- Section 4(f) – Commitment to public interest
- Violation constitutes ground for administrative disciplinary action
Republic Act No. 11036 (Mental Health Act) and DOLE Department Order No. 208, series of 2020
- Employers (including DepEd) must develop policies to prevent psychological harm, including bullying and harassment
Republic Act No. 7877 (Anti-Sexual Harassment Act of 1995) and Republic Act No. 11313 (Safe Spaces Act of 2018)
- Apply when the verbal harassment is gender-based or sexual in nature (e.g., sexist remarks, unwelcome sexual comments, catcalling, or persistent sexual jokes)
- Duty of the employer (DepEd) to prevent, investigate, and punish

IV. Administrative Remedies (Primary and Most Effective Remedy)

Public school personnel are civil servants. The most potent and commonly successful remedy is the administrative case.

A. Applicable Rules

2017 Rules on Administrative Cases in the Civil Service (CSC Resolution No. 1701077)
DepEd Order No. 49, s. 2006 (Revised Rules of Procedure in Administrative Cases)
DepEd Order No. 35, s. 2004 (Grievance Machinery)

B. Grounds Most Frequently Used

Grave Misconduct
Conduct Prejudicial to the Best Interest of the Service
Oppression
Abuse of Authority
Disgraceful and Immoral Conduct
Violation of RA 6713

Verbal abuse, especially when repeated and done publicly, is consistently classified by the CSC and Supreme Court as Conduct Prejudicial or Grave Misconduct.

C. Procedure

Informal Grievance (Recommended First Step)
- File written grievance with the school-level Grievance Committee within 15 days of the incident
- DepEd Order No. 35, s. 2004
Formal Complaint
- File verified complaint with:
  a. School Principal (if superior is head teacher)
  b. Schools Division Superintendent
  c. Regional Director
  d. Central Office (Secretary) for grave offenses
- Complaint may also be filed directly with the Civil Service Commission Regional Office
Investigation and Hearing
- Fact-finding investigation within 5 days
- Formal charge issued if prima facie case exists
- Respondent given 5 days to answer
- Formal investigation and decision within 30–90 days
Penalties (CSC Uniform Rules)
- 1st offense Conduct Prejudicial – Suspension 1 month 1 day to 6 months
- 2nd offense – Dismissal
- Grave Misconduct or Oppression – Dismissal on first offense
- Accessory penalties: perpetual disqualification from government service, cancellation of civil service eligibility, forfeiture of retirement benefits

D. Notable Supreme Court Decisions Upholding Dismissal for Verbal Abuse

G.R. No. 242440 (2021) – Principal dismissed for repeatedly shouting "putang ina mo" and other profane language at teachers
CSC v. Sta. Ana (G.R. No. 212042, 2016) – Public school principal dismissed for verbal abuse and public humiliation of subordinates
Re: Principal Macalino (A.M. No. 2019-22-SC) – Dismissal for calling teachers "mga hayop" and other degrading remarks
DepEd v. Foreman (G.R. No. 241495, 2020) – Supervisor dismissed for sustained verbal harassment and threats

These cases confirm that even a single serious instance of profane verbal abuse, when committed by a superior, can justify dismissal.

V. Criminal Remedies

Oral Defamation/Slander (Articles 353–359, Revised Penal Code)
- Public and malicious imputation of a vice or defect
- Penalty: Arresto mayor (1 month 1 day to 6 months) and fine
- Grave slander if highly scandalous words (e.g., accusing immorality)
Unjust Vexation (Article 287, RPC)
- Any act that annoys or irritates without justification
- Penalty: Arresto menor or fine
Light Threats (Article 283, RPC)
- If the superior threatens undesirable transfer or harm
Alarms and Scandals (Article 155, RPC)
- Shouting profanities in school premises
Violation of RA 11313 (Safe Spaces Act) – if gender-based
- Penalty: Fine of ₱100,000–₱300,000 and/or imprisonment 6 months–6 years for severe cases

Criminal cases are filed with the Office of the City/Provincial Prosecutor. While conviction rates are lower than administrative cases, a criminal complaint exerts strong pressure and may be used as evidence in the administrative case.

VI. Civil Remedies

Action for Damages under Articles 19, 20, 21, 26, 32, 33, 34, and 2176 of the Civil Code
- Moral damages (besmirched reputation, mental anguish, wounded feelings)
- Exemplary damages
- Attorney’s fees
Amounts Awarded in Similar Cases
- ₱50,000–₱300,000 moral damages common when harassment is proven
- Higher if victim suffered depression requiring medical treatment
Venue
- Regional Trial Court of the place where plaintiff or defendant resides

VII. Special Procedure for Gender-Based or Sexual Harassment

Every public school must have a Committee on Decorum and Investigation (CODI) pursuant to CSC Resolution No. 01-0940 and RA 11313.

Complaint filed with CODI within 6 months (RA 11313)
Investigation completed within 30 days
Penalties identical to administrative cases
Appeal to CSC or DepEd Secretary

VIII. Other Remedies and Support Mechanisms

Office of the Ombudsman
- If the act constitutes oppression by a public officer (Section 15, RA 6770)
Commission on Human Rights
- For investigation of human rights violations (dignity)
Transfer Request
- Victim may request compassionate transfer via DepEd Regional Director
Psychological Support
- Under RA 11036 and DepEd’s Employee Welfare Division

IX. Evidentiary Tips for Complainants

Record audio/video when safe and legal (RA 4200 allows recording if you are a party to the conversation)
Secure affidavits from witnesses (fellow teachers, pupils’ parents)
Keep logbook of incidents with dates, time, exact words used
Secure medical certificate if stress caused illness
Save text messages, Messenger chats, or emails

X. Conclusion

Public school teachers and staff subjected to bullying and verbal harassment by superiors possess powerful legal tools for redress. The administrative route offers the highest probability of success, with dismissal of the perpetrator being a realistic and frequently imposed penalty. The Supreme Court has consistently upheld such dismissals, sending a clear message that the Department of Education will not tolerate abuse of authority that undermines the dignity of its teaching force.

Victims must act promptly, document thoroughly, and avail themselves of the grievance machinery or directly file formal charges. Silence only perpetuates the culture of fear; decisive legal action protects not only the individual teacher but the entire public school system.