Camacho v. Coresis, Jr.
REITERATIONFacts
The Antecedents: Petitioner, Dean Manuel Camacho, filed administrative and criminal complaints against Dr. Sixto O. Daleon, a professor at the University of Southeastern Philippines (USP), and three students (Agulo, Alaba, and Tecson), along with the Board of Regents and other university officials. The complaint stemmed from Dr. Daleon allegedly giving passing grades to the three students in a graduate course (Ed.D. 317) without requiring them to attend regular classes. Petitioner alleged these were "ghost students" and requested documentation, which Dr. Daleon initially ignored. Procedural History: The matter was investigated by the Office of the Ombudsman-Mindanao. The Ombudsman, through Graft Investigation Officer I Atty. Jovito A. Coresis, Jr., issued a Resolution on June 3, 1997, dismissing both the administrative and criminal complaints for insufficient evidence and lack of prima facie case, respectively. Petitioner's motion for reconsideration was denied on September 10, 1997. The Petition: Petitioner filed a petition for certiorari before the Supreme Court, alleging grave abuse of discretion, misapplication of academic freedom, and due process violations by the Ombudsman.
Issue(s)
Whether public respondents committed grave abuse of discretion amounting to lack of jurisdiction in exonerating Dr. Daleon from administrative and criminal liability for giving passing grades to students without requiring them to attend classes. Whether the Board of Regents' resolutions upholding the grades were ultra vires and contrary to the University Code. Whether academic freedom was misapplied to absolve respondents. Whether the Ombudsman's findings and conclusions were based on self-serving, incredible, and hearsay proffers, violating due process.
Ruling
The Supreme Court dismissed the petition for lack of merit and affirmed the Resolution dated June 3, 1997, of the Office of the Ombudsman-Mindanao.
Ratio Decidendi
On the issue of grave abuse of discretion and the Ombudsman's findings: The Court found no grave abuse of discretion on the part of the Ombudsman. The resolution was based on substantial evidence, including the counter-affidavit of Dr. Daleon corroborated by an affidavit from Professor Concesa P. Lagare. This evidence indicated that the Vice President for Academic Affairs had previously stated that special arrangements between professors and graduate students could be allowed on a case-to-case basis. The Ombudsman's conclusions were supported by the records and did not constitute a patent due process violation. The Court found no basis to hold that Dr. Daleon and the Board of Regents acted in evident bad faith or with manifest partiality. The Ombudsman's dismissal of the criminal charges for violation of R.A. 3019 was therefore justified. On the Board of Regents' resolutions and the University Code: The Court noted that Dr. Daleon was the Officer-In-Charge (OIC) of the Graduate School and, as such, performed the functions of the Dean. Article 140 of the University Code allowed the Dean to modify rules on attendance for graduate students. Therefore, Dr. Daleon had the authority to modify the attendance rule without seeking permission from the petitioner. The Board of Regents, as the body with the authority to formulate university policies, validated Dr. Daleon's teaching style by passing Resolution No. 2432, S. 1995. This resolution upheld the grade given to Agulo and implicitly approved Dr. Daleon's instructional approach. The Board cited Article 155 (no grade change after submission) and Article 3 (faculty member's academic freedom) of the University Code. On the application of academic freedom: The Court emphasized that institutional academic freedom includes the freedom to determine "how it shall be taught," thus validating the school's right to confirm Dr. Daleon's teaching method. The Court reiterated that academic freedom, as guaranteed by the Constitution, is two-tiered: institutional and individual. For teachers, it means the right to pursue studies and communicate conclusions without interference. In this case, academic freedom gave Dr. Daleon the latitude to innovate teaching methods, especially for graduate students, subject to university policies. On the alleged due process violation: Since the Board of Regents validated his method, the petitioner's contrary opinion did not warrant a complaint before the Supreme Court.
Main Doctrine
The Supreme Court affirmed the dismissal of administrative and criminal complaints against a university professor and officials, finding no grave abuse of discretion on the part of the Ombudsman in upholding the professor's authority to grant special arrangements for graduate students, supported by university policies and the principle of academic freedom.