Facts:
Petitioner
Dr. Manuel Camacho, Dean of the College of Education of the
University of Southeastern Philippines (USP), assailed the September 9, 1997 decision of the
Court of Appeals in
CA-G.R. SP No. 42860, which affirmed the Regional Trial Court (RTC) of Davao City, Branch 33, resolution denying his petition for
prohibition against respondents as members of the
Board of Regents of the USP and as members of its
Special Investigation Committee, and against
Hon. Wenceslao Ibabao in his capacity as Presiding Judge of Davao City. The controversy began in June 1995 when several doctorate students complained to petitioner of “
ghost students” in Dr. Sixto Daleon’s Ed. D. 317 class during the first semester of school year 1994–1995, for which passing grades were reportedly given despite unjustified absences. Petitioner relayed the matter to the USP President
Edmundo Prantilla and to the
Board of Regents, where
DECS Secretary Ricardo Gloria sat as chairman; on December 23, 1995, the Board of Regents passed
Resolution No. 2432 upholding the passing grade given to Aida Agulo. Petitioner then filed on January 25, 1996 a complaint before the
Office of the Ombudsman-Mindanao for
gross incompetence and
insubordination against Dr. Daleon, later amending it to include the Board of Regents chaired by then DECS Secretary Gloria, DECS Legal Officer Reno Capinpin, and the three students who allegedly received passing grades despite absences (Aida Agulo, Desiderio Alaba, and Norma Tecson). On June 3, 1997, Graft Investigator Atty. Jovito Coresis, Jr. dismissed the Ombudsman complaint, which was approved by Ombudsman Aniano Desierto; this Court later affirmed the dismissal in
Camacho v. Coresis, Jr., G.R. No. 134372, August 22, 2002. Meanwhile, on February 21, 1996,
Dr. Thelma S. Ledesma, Secretary of the Board of Regents of USP, filed with the Office of the USP President a complaint against petitioner for
grave misconduct,
conduct unbecoming of a dean, and
falsification of public documents; this was docketed as
Administrative Case No. 001. The administrative complaint alleged that petitioner rigged the results of a student performance evaluation test to justify his failure to give her any teaching assignment. Acting on Administrative Case No. 001, Secretary Gloria as Board chairman created a
Special Investigation Committee (SIC) composed of DECS Assistant Secretary
Reno A. Capinpin (Chairman), and members
Leovigildo P. Arellano and
Cesar M. Limbaga. During the preliminary conference on August 1, 1996, petitioner moved for
inhibition of the committee members, asserting that the committee was improperly constituted because Gloria and Capinpin were respondents in the Ombudsman case he had filed. On August 19, 1996, the SIC denied the motion to inhibit and set the hearing for August 22, 1996. On August 21, 1996, petitioner filed a petition for
prohibition with prayer for a
temporary restraining order before the RTC in
Civil Case No. 24,606-96, naming Secretary Gloria and the SIC members, seeking to restrain the committee from hearing Administrative Case No. 001 on the ground that the committee’s creation violated his right to due process. The RTC initially issued a temporary restraining order, but respondents moved to dismiss on grounds including
lack of cause of action,
insufficiency of the petition, and
non-exhaustion of administrative remedies; petitioner opposed and Dr. Ledesma moved to intervene. In a resolution dated October 14, 1996, the RTC dismissed the petition for prohibition, reasoning that petitioner should have exhausted administrative remedies by submitting to the committee’s investigation and then, if adverse, appealing to the
Secretary of Education and thereafter to the
Office of the President; the RTC denied reconsideration on November 14, 1996. Petitioner then sought certiorari in the Court of Appeals, which denied the petition and the subsequent motion for reconsideration for lack of merit on September 9, 1997. Before the Supreme Court, petitioner raised, in essence, whether administrative exhaustion was a condition precedent to judicial relief, whether USP’s charter repealed pertinent Civil Service rules and the
Magna Carta for Public School Teachers, whether
R.A. 7722 divested DECS of jurisdiction over tertiary institutions, and whether the SIC had jurisdiction to hear Administrative Case No. 001, as well as whether the committee violated due process through alleged bias.
Issues:
Whether the
Board of Regents of the University of Southeastern Philippines, through its
Special Investigation Committee, had jurisdiction over
Administrative Case No. 001 and whether petitioner’s
right to due process was violated by the committee’s formation.
Ruling:
Ratio:
Doctrine: