Case Digest (G.R. No. 134625) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In University of the Philippines Board of Regents et al. versus the Court of Appeals and Arokiaswamy William Margaret Celine, private respondent, an Indian national on a Philippine visitor’s visa, enrolled in the U.P. doctoral program in Anthropology in April 1988. After completing coursework, she took a two-year leave to work in Rome, returning July 1991 to finish her dissertation on “Tamil Influences in Malaysia, Indonesia and the Philippines.” Upon the recommendation of her adviser, her oral defense was scheduled for February 5, 1993, notwithstanding a panel member’s report of unacknowledged passages lifted from published sources. Four of five panelists signed her approval form, while the dean’s representative and one member withheld endorsement pending documentary revisions. Relying on the majority, Dean Consuelo Paz cleared the dissertation and the University Council recommended graduation, which the Board of Regents approved; respondent received her Ph.D. on April 24, 1993 Case Digest (G.R. No. 134625) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Pre‐defense and dissertation completion
- Arokiaswamy William Margaret Celine, an Indian citizen with a Philippine visitor’s visa, enrolled in the Ph.D. program in Anthropology at UP–Diliman in April 1988, completed coursework, and took leave to work abroad from 1989 to 1991.
- She returned in July 1991, wrote a dissertation on “Tamil Influences in Malaysia, Indonesia and the Philippines,” and was certified ready for oral defense in December 1992.
- Oral defense and initial approval with reservations
- The defense panel (Drs. Manuel, Quiason, Skandarajah, Teodoro, and Dean’s rep. Medina) met on February 5, 1993. Four panelists signed approval forms, each attaching conditions for revisions; Dr. Medina withheld his signature pending review of revisions.
- Respondent sought and attended a faculty meeting on March 5, 1993; Dean Paz declared majority approval sufficient. The CSSP Faculty Assembly approved her graduation, pending final copies, in March 1993. Respondent submitted revised drafts in April 1993 to three panelists, but not to Drs. Medina and Teodoro.
- Administrative inquiries and degree revocation
- Dean Paz formed an ad hoc “Ventura Committee” (May 1993) which, by June 15, 1993, found at least 90 instances of unacknowledged lifting of text. The CSSP Assembly (July 28) and University Council (August 16) recommended degree withdrawal; the Board deferred action.
- Chancellor Roman convened meetings with respondent (September–October 1993) and received written explanations. A special external “Zafaralla Committee” (August 1994) corroborated massive plagiarism. The Board of Regents, in November and December 1994 meetings, resolved by majority to withdraw her Ph.D. degree.
- Judicial proceedings
- Respondent petitioned the RTC for mandamus (Aug. 1995), alleging undue withdrawal without due process; the trial court dismissed the petition (Aug. 1996).
- The Court of Appeals reversed (Dec. 1997), ordering restoration of the degree; UP appealed to the Supreme Court.
Issues:
- Did the Court of Appeals err in issuing a writ of mandamus to restore the withdrawn Ph.D. degree?
- Did revocation of the degree violate respondent’s rights to intellectual property and to justice and equity?
- Was respondent deprived of substantive and procedural due process in the academic withdrawal proceedings?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)