Case Summary (G.R. No. 200080)
Dissertation Completion and Alleged Plagiarism
After finishing coursework and taking leave abroad, respondent returned in July 1991 to complete her dissertation, “Tamil Influences in Malaysia, Indonesia and the Philippines.” In February 1993, she defended the work before a five-member panel. Dean’s representative Dr. Isagani Medina identified unacknowledged liftings from Balfour’s Cyclopaedia and a Royal Asiatic Society journal. Despite this, four panelists signed an approval form, with two conditioning final consent on revisions.
Administrative Proceedings and Degree Conferment
Respondent met with panel members and Dean Paz, who opined that a majority vote was sufficient despite Medina’s withheld signature. The CSSP College Assembly recommended graduation pending final copies. Respondent submitted revised drafts to three panelists who approved them; Medina and Dr. Noel Teodoro did not. Dean Paz nonetheless accepted the dissertation. The University Council and Board of Regents, unaware of the pending controversy, approved respondent’s graduation, and she received her Ph.D. on April 24, 1993.
Investigation and Recommendations for Degree Withdrawal
Dr. Medina formally charged respondent with plagiarism. Dean Paz convened an ad hoc Ventura Committee, which found some ninety instances of unacknowledged copying. The CSSP assembly and University Council recommended withdrawal of the degree; the Board of Regents deferred action pending legal review. Chancellor Roman gave respondent notice and multiple opportunities to explain. An external Zafaralla Committee reaffirmed massive plagiarism. By majority vote in November–December 1994, the Board of Regents resolved to withdraw her doctoral degree.
Academic Freedom and Jurisdictional Framework
Under Article XIV, Section 5(2) of the 1987 Constitution, UP enjoys academic freedom and institutional autonomy. Act No. 1870 delegates to the Board of Regents the power to confer degrees (Section 4) and to act on recommendations of the University Council (Section 9). Mandamus will not issue to control discretionary academic decisions.
Due Process in University Administrative Proceedings
Due process in this context requires notice and a fair opportunity to be heard, not judicial-style trial procedures. Respondent received written charges, submitted detailed explanations, and participated in investigative meetings. Multiple committees considered her explanations. Absent proof to the contrary, the regularity of these proceedings is presumed.
Power to Withdraw Fraudulently Obtained Degrees
A university may revok
...continue readingCase Syllabus (G.R. No. 200080)
Facts
- Private respondent Arokiaswamy William Margaret Celine, an Indian citizen with a Philippine visitor’s visa, enrolled in April 1988 in the Ph.D. program in Anthropology at UP CSSP, Diliman.
- After completing coursework, she took a two-year leave to work in Rome (Tamil Programme Producer, Vatican Radio; General Office Assistant, International Right to Life Federation).
- July 1991: returned to the Philippines to work on her dissertation, “Tamil Influences in Malaysia, Indonesia and the Philippines.”
- December 22, 1992: Dr. Realidad Rolda certified her readiness for oral defense; initially scheduled January 6, 1993, but rescheduled to February 5, 1993 by Dr. Maria Serena Diokno.
- Dissertation panel: Drs. E. Arsenio Manuel, Serafin Quiason, Sri Skandarajah, Noel Teodoro, and Isagani Medina (dean’s representative).
- Dr. Medina reported portions of the dissertation lifted without acknowledgment from Balfour’s Cyclopaedia (1967 reprint) and John Edye’s 1833 article; nonetheless, defense proceeded.
- February 5, 1993: Four panelists (Manuel, Quiason, Skandarajah, Teodoro) signed approval; Quiason and Teodoro added conditions on revisions; Medina withheld signature pending review of revisions.
- March 5, 1993: Private respondent requested meeting with panel; Dean Paz stated majority vote was sufficient despite Medina’s non-consent.
- March 24, 1993: CSSP College Faculty Assembly approved graduation pending final dissertation submission.
- April 1993: Private respondent submitted revised drafts to Manuel, Skandarajah, Quiason (approved); did not secure Medina’s or Teodoro’s signature; proceeded on majority rule.
- April 17–21, 1993: Private respondent wrote letters expressing disappointment and accusations against administrators; Dean Paz sought exclusion of her name from graduation list pending clarification; Board of Regents approved graduation recommendation on April 22; Celine graduated April 24, 1993.
Administrative Proceedings
- April 21, 1993: Dean Paz conditioned academic clearance on substantiation of respondent’s allegations; respondent replied April 27, sought to justify omission of signatures and accused Diokno of harassment.
- May 1, 1993: Dr. Medina formally charged plagiarism and recommended withdrawal of the Ph.D.
- May 13, 1993: Dean Paz constituted the Ventura Committee to investigate plagiarism; recommended withdrawal to Chancellor Roman.
- June 15, 1993: Ventura Committee found at least 90 unacknowledged liftings; July 28 CSSP Assembly and August 16 University Council recommended withdrawal to Board of Regents.
- September 6, 1993: Board deferred action, studying legal ramifications.
- September 23–October 1993: Chancellor Roman summoned respondent, ga