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 Summary (G.R. No. 211362)

Parties

Petitioners: Renato P. Cudia (for himself and on behalf of Cadet Cudia), Berteni CataluAa Causing, and intervenor Filipina P. Cudia.
Respondents: PMA Superintendent, PMA Honor Committee (2014) and its members, and the Cadet Review and Appeals Board.

Key Dates

– November 14, 2013: Cadet Cudia allegedly late to ENG412 class.
– December 19, 2013: CTO metes out demerits and touring hours.
– January 21, 2014: Formal HC hearing and 9–0 guilty verdict for lying.
– February 10, 2014: Indefinite leave of absence ordered.
– March 10, 2014: CRAB upholds dismissal.
– March 16, 2014: PMA graduation without Cadet Cudia.
– June 11, 2014: President sustains AFP Chief of Staff and CRAB findings.
– February 24, 2015: Supreme Court decision.

Applicable Law

1987 Constitution (academic freedom; due process; civilian supremacy).
Commonwealth Act No. 1 (National Defense Act) on PMA governance.
PMA Honor Code and Honor System Handbook (Series 2011).
AFP Cadet Corps Administrative and Operational Policies and Regulations (CCAFPR S-2008).
Rules of Court, Rule 65 (writ of mandamus) and Rule 131 (presumptions).

Procedural Antecedents

Petition for certiorari, prohibition, and mandamus filed days before the March 16, 2014 graduation. TRO denied; intervention by Filipina Cudia granted. CHR Final Investigation Report admitted. Respondents filed consolidated comment; petitioners filed reply with additional CHR resolution. Multiple motions for early resolution noted by the Court.

Facts

Cadet Cudia received a delinquency report for alleged two-minute tardiness to his 1505–1605H ENG412 class, claiming the prior OR432 class was dismissed “a bit late.” He received 11 demerits and 13 touring hours, but his written appeal to the Senior Tactical Officer was denied. Major Hindang reported him to the Honor Committee for “lying” in that appeal. After preliminary and formal HC investigations (with telephonic testimony by Dr. Costales), the HC found him guilty by unanimous secret ballot. The decision was reviewed and affirmed by the HC OIC, Staff Judge Advocate, Commandant of Cadets, Superintendent, HTG inquiry, CRAB (twice), and Fact-Finding Board. Appeals to the AFP Chief of Staff and the President were denied. The CHR-CAR found probable cause of due process violations and recommended exoneration, but its findings were recommendatory.

Issues

  1. Whether respondents committed grave abuse of discretion and denied due process in dismissing Cadet Cudia.
  2. Whether Cadet Cudia’s statements constituted “lying” under the Honor Code.
  3. Whether CHR findings are binding or of persuasive weight.

Ruling of the Court

– Writ of mandamus was improper: inclusion in graduation roll, awards, and commissioning are discretionary academic matters falling under PMA’s academic freedom.
– Court has jurisdiction via certiorari to review grave abuse of discretion despite pending administrative processes; supervening presidential denial rendered exhaustion issues moot.
– Military cadets retain due process rights in PMA disciplinary proceedings; hearings met minimum standards (notice, opportunity to answer, presentation of evidence, deliberation). Formal counsel was not indispensable. Confidentiality and alleged ostracism orders were not legally proven.
– PMA enjoys institutional

...continue reading

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.

About Privacy Terms