To me, it would only mean that in a very definite context. If someone just said to me, "He's a strong teacher", I don't think I'd assume that meaning. However, this may be because I've been teaching ESL/EFL for so long and have heard 'strong teacher' used incorrectly to mean 'strict teacher' so often. That might be colouring my interpretation. For me, 'he has strong teaching skills' is much clearer.