Title
Cudia vs. Superintendent of the Philippine Military Academy
Case
G.R. No. 211362
Decision Date
Feb 24, 2015
Cadet Cudia, PMA salutatorian, dismissed for alleged Honor Code violation; Supreme Court ruled denial of due process, ordered reinstatement and graduation.

Case Digest (G.R. No. 219590)
Expanded Legal Reasoning Model

Facts:

  • Procedural Antecedents
    • Petition filed by Renato P. Cudia (on his own behalf and for Cadet 1CL Aldrin Jeff P. Cudia) and Berteni CataluAa Causing for certiorari, prohibition, and mandamus with TRO application (March 2014).
    • Filipina P. Cudia intervened; CHR Final Investigation Report admitted; respondents filed consolidated comment; petitioners replied.
  • Tardiness and Honor Committee Proceedings
    • On 14 November 2013, Cadet Cudia was reported two (2) minutes late for his 5th-period ENG412 class after OR432; he explained his OR432 class was “dismissed a bit late.”
    • CTO Maj. Hindang imposed 11 demerits and 13 touring hours; request for reconsideration denied; an Honor Report for “lying” was filed.
  • Formal Honor Investigation
    • Foxtrot Company conducted a preliminary inquiry; recommended formalization.
    • Formal hearing (20-21 January 2014): Cudia pleaded not guilty; testimony from Maj. Hindang, Dr. Costales (via phone), fellow cadets; secret ballot initially 8-1 guilty; dissenting vote reconsidered in an “executive session,” final tally 9-0 guilty.
  • Administrative Reviews and Separation
    • HTG informal review, SJA endorsement, Commandant and Superintendent affirmed findings; Special Orders placed Cudia on indefinite leave without pay and ostracism order by cadets.
    • CRAB review upheld dismissal; Fact-Finding Board also denied appeal; President’s Executive Secretary affirmed all prior findings (June 2014).

Issues:

  • Whether Cadet Cudia was denied due process (access to evidence, counsel, confidentiality, vague and delayed decisions, sham hearings, ostracism).
  • Whether the PMA and its bodies exceeded their authority and misapplied the Honor Code to dismiss a cadet.
  • Whether academic freedom and military discipline permit dismissal for an Honor Code violation.
  • Whether CHR findings bind the Court or warrant reversal.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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