Case Digest (G.R. No. 134372)
Facts:
The case involves Manuel Camacho as the petitioner against several respondents, including Atty. Jovito A. Coresis, Jr., Graft Investigation Officer I of the Office of the Ombudsman-Mindanao, and Dr. Sixto O. Daleon, among others, including faculty members and the Board of Regents of the University of Southeastern Philippines (USP). The events leading to the case began in the first semester of the 1994-1995 academic year when Dr. Daleon, a professor at USP, provided passing grades to three students—Aida Agulo, Desiderio Alaba, and Norma Tecson—without requiring them to attend regular classes. Instead, he offered them a special self-study program. Complaints arose from other doctoral students regarding the presence of "ghost students" in Dr. Daleon's class, leading Camacho, the Dean of the College of Education, to request documentation from Dr. Daleon, which he ignored. Following a university council meeting, an investigation was initiated, and Dr. Daleon admitted...
Case Digest (G.R. No. 134372)
Facts:
Background of the Parties:
- Petitioner Manuel Camacho is the Dean of the College of Education at the University of Southeastern Philippines (USP), serving since January 1994 and having been a faculty member and administrator for nearly 13 years.
- Respondent Dr. Sixto O. Daleon is a Professor 6 and Officer-in-Charge (OIC) of the Graduate School at USP, with a salary grade of CS 29.
- Other respondents, Aida Agulo, Desiderio Alaba, and Norma Tecson, are faculty members of USP who enrolled in Dr. Daleon’s Ed.D. 317 (Seminar in Curriculum Development) during the first semester of 1994-1995.
The Allegations:
- Dr. Daleon gave Agulo, Alaba, and Tecson passing grades (1.0, 1.25, and 1.5, respectively) without requiring them to attend regular classes. Instead, he provided a special program of self-study, weekly tutorial meetings, quizzes, and term papers.
- In June 1995, doctoral students complained to Camacho about "ghost students" in Dr. Daleon’s class, alleging that Agulo, Alaba, and Tecson received passing grades despite not attending classes.
Investigation and University Proceedings:
- Camacho requested Dr. Daleon to provide records of exams, term papers, and attendance, but Dr. Daleon ignored the request.
- The matter was raised in a university council meeting, and a committee was created to investigate the complaint.
- Dr. Daleon later admitted to making special arrangements for the students without Camacho’s approval.
- Camacho recommended that the students attend regular classes and comply with course requirements, which was approved by USP President Dr. Edmundo Prantilla.
- However, Dr. Prantilla later entertained an appeal from Agulo to validate the grades given by Dr. Daleon, and the Board of Regents upheld the grades in Resolution No. 2432.
Ombudsman Proceedings:
- Camacho filed a Complaint-Affidavit against Dr. Daleon and others before the Office of the Ombudsman-Mindanao, alleging gross incompetence, insubordination, and violations of R.A. 3019 (Anti-Graft and Corrupt Practices Act).
- The Ombudsman dismissed the complaints, finding insufficient evidence to hold Dr. Daleon liable and no prima facie case for violation of R.A. 3019.
Issue:
- Whether the Office of the Ombudsman-Mindanao committed grave abuse of discretion in dismissing the administrative and criminal complaints against Dr. Daleon and others.
- Whether the Board of Regents’ resolution upholding Dr. Daleon’s grading was contrary to the University Code and violated due process.
- Whether the principle of academic freedom was misapplied to absolve Dr. Daleon and the Board of Regents of liability.
Ruling:
The Supreme Court dismissed the petition for lack of merit, affirming the Ombudsman’s resolution. The Court held that:
- The Ombudsman did not commit grave abuse of discretion, as its findings were based on substantial evidence.
- Dr. Daleon, as OIC of the Graduate School, had the authority to modify attendance rules for graduate students under the University Code.
- The Board of Regents’ resolution validating Dr. Daleon’s grading was a valid exercise of its discretion and consistent with academic freedom.
- Academic freedom, both institutional and individual, protected Dr. Daleon’s teaching methods and the Board’s decision to uphold his grading.
Ratio:
- Grave Abuse of Discretion: The Ombudsman’s findings were supported by substantial evidence, including affidavits and the University Code. There was no showing of bad faith or manifest partiality in the Ombudsman’s decision.
- Authority of Dr. Daleon: As OIC of the Graduate School, Dr. Daleon had the authority to modify attendance rules for graduate students without seeking Camacho’s approval.
- Academic Freedom: The constitutional guarantee of academic freedom protects the right of educational institutions and faculty members to determine teaching methods and policies. The Board of Regents’ validation of Dr. Daleon’s grading was consistent with this principle.
- Due Process: The Ombudsman’s resolution was based on credible evidence and did not violate due process. The Board of Regents’ decision was also a valid interpretation of university policies.
Conclusion:
The Supreme Court upheld the Ombudsman’s dismissal of the complaints, finding no grave abuse of discretion and affirming the primacy of academic freedom in higher education institutions.