Last year, the Department of Education issued DepEd Order 39, which directed private educational institutions to refrain from using the English and Science series of textbooks of a Philippine publisher on the basis of the findings of the Department’s Instructional Materials Council Secretariat (IMCS).
The private schools and their associations should seriously determine whether or not such an Order encroaches on their autonomy and their prerogative to decide which textbooks to select for their students. As far as I know, no particular law authorizes the DepEd to micro-manage private schools to the point of telling them the specific books to refrain from using. While the DepEd has full authority to select the basic education textbooks for the public school system, it does not have the authority to regulate the private school textbook market. At most, the DepEd can issue advisories to private schools on which textbooks in the market are quality books and which are not.
Another problematic matter about the Order is that the IMCS has no published procedure on how it undertakes evaluation of private school textbooks, nor does it have published criteria and specifications on what constitutes an erroneous or poor quality private school textbook. The current procedure of the IMCS is for the evaluation and procurement of textbooks for public schools. Also, the IMCS has no published procedure that gives a publisher an opportunity to adequately respond to or dispute its findings. When DepEd Order 39 was issued, the publisher had not yet received the detailed findings of the IMCS. Was this fair? Was there due process?
I recommend that adequate consultation with private school educators, publishers, and their associations be conducted before the IMCS criteria and procedure be published and implemented. Without adequate consultation on the criteria and procedure, the IMCS might end up becoming an arbitrary textbook regulator, while it has not yet established a reputation for integrity and objectivity.
Is the IMCS already a reliable judge on the quality of textbooks, and has corruption in the IMCS been effectively addressed? If the private educational institutions simply accepted another DepEd Order banning another set of textbooks they procured, the time might come when the IMCS would become the ultimate determinant of which textbooks would be used in the private schools.