G.R. No. 161172 - Morales vs. Board of Regents of the University of the Philippines

Petitioner Nadine Rosario M. Morales initially enrolled at UP Manila taking up Speech Pathology and later transferred to UP Diliman, enrolling in the BA European Languages program under the College of Arts and Letters.
Upon transfer, she opted for the Plan A curriculum, selecting French as her major and initially German as her minor.
During the first semester of school year 1997-1998, she enrolled in German 10 and German 11, obtaining grades of 1.0 in each.

At the beginning of the second semester, the petitioner changed her minor from German to Spanish while maintaining French as her major.
The College of Arts and Letters initially included her German grades in the computation of her General Weighted Average (GWA), which resulted in her being placed in the list for probable graduation with honors based on a computed GWA of 1.725 (later adjusted to 1.729 with additional subjects).
During the final assessment, the university excluded her German 10 and 11 grades from the computation because they did not fit the requirements of her revised curriculum under Plan A (which does not allow free electives and requires that electives conform to specific course sequencing and language requirements).

Following the exclusion of her German grades, the petitioner and her parents initiated administrative appeals by writing to key university officials and subsequently presenting the issue before:

The University Council deliberated on the issue on 10 April 2000 (and again on 21 June 2000) and determined that the petitioner’s German courses should not be considered as qualifying electives under her curriculum.
The Board of Regents, in its meeting on 31 August 2000, upheld the decision by a vote of 9 against 2, thereby denying her appeal to include her German grades and confer cum laude honors.
Petitioner subsequently instituted a petition for certiorari and mandamus before the Regional Trial Court (RTC) on 21 March 2001, which ruled in her favor on 05 September 2002, ordering the inclusion of her German 10 and 11 grades in the GWA computation.
The respondent filed a Motion for Reconsideration (denied) and appealed the RTC’s decision to the Court of Appeals, leading to the subsequent series of reviews addressing both jurisdiction and academic freedom issues.

Central to the dispute was the interpretation of Article 410 of the UP Code governing the conferment of academic honors, which sets the minimum weighted average grades for Summa Cum Laude, Magna Cum Laude, and Cum Laude distinctions.
The provision also specifies that “all the grades in all subjects prescribed in the curriculum” and “subjects that qualify as electives” must be included in the computation, subject to a prescribed procedure in case the number of electives exceeds the requirements.
The petitioner argued that her German grades must be counted because, under her prior enrollment, they contributed to a GWA above the cum laude threshold.
Conversely, university officials maintained that, since the petitioner changed her minor, the German courses were extraneous to her Plan A curriculum requirements.

Whether the appeal raised by the respondent UP Board of Regents before the Court of Appeals involved only questions of law, given that the facts were undisputed, thus making the proper mode of appeal a petition for review on certiorari rather than through a notice of appeal.

Whether or not the exclusion of the petitioner’s grades in German 10 and 11 from the computation of her General Weighted Average amounted to a grave abuse of discretion by the university.
Whether the German courses could be counted as “subjects that qualify as electives” under the relevant provision of the UP Code in light of curriculum requirements whereby the student’s minor and major must conform to predetermined course sequences.

Whether the lower court, in ordering the re-computation of the petitioner’s GWA and conferring cum laude honors, improperly interfered with the University’s autonomy and its constitutional right to academic freedom.
Whether a court should substitute its interpretation of internal academic rules for that of the university’s established regulatory bodies (Department, College, University Council, and Board of Regents).