Camacho v. Gloria
REITERATIONFacts
The Antecedents: Petitioner Manuel Camacho, Dean of the College of Education of the University of Southeastern Philippines (USP), reported alleged "ghost students" receiving passing grades in a class, which led to a Board of Regents (BOR) resolution upholding the grade. Petitioner filed a complaint with the Ombudsman against Dr. Sixto Daleon, the BOR, and others, which was later dismissed. Subsequently, Dr. Thelma S. Ledesma filed a complaint against petitioner for grave misconduct, conduct unbecoming of a dean, and falsification of public documents. The BOR Chairman, DECS Secretary Ricardo Gloria, created a Special Investigation Committee (SIC) to investigate. Petitioner moved for the inhibition of SIC members, citing their involvement as respondents in his Ombudsman case, but the motion was denied. Procedural History: Petitioner filed a petition for prohibition with a temporary restraining order before the Regional Trial Court (RTC) of Davao City, seeking to restrain the SIC from hearing the administrative case, alleging violation of due process. The RTC issued a TRO but later dismissed the petition, ruling that petitioner failed to exhaust administrative remedies. The Court of Appeals affirmed the RTC's decision. The Petition: Petitioner seeks review of the Court of Appeals' decision, raising issues on exhaustion of administrative remedies, the effect of BP Blg. 12 and RA 7722 on civil service rules and DECS jurisdiction, and the SIC's jurisdiction over Administrative Case No. 001.
Issue(s)
Whether or not the Board of Regents of USP, through the Special Investigation Committee, has jurisdiction over Administrative Case No. 001. Whether or not petitioner's right to due process was violated by the Special Investigation Committee of the university. Whether or not exhaustion of administrative remedies is a condition precedent to judicial relief. Whether or not the passage of B.P. Blg. 12 repealed pertinent provisions of civil service rules and the Magna Carta for public school teachers, and whether or not R.A. 7722 divested the DECS Secretary of his jurisdiction over tertiary institutions.
Ruling
The Supreme Court denied the petition for lack of merit, affirming the decision of the Court of Appeals. The Court held that the Board of Regents has jurisdiction over the administrative case and that the petitioner's right to due process was not violated.
Ratio Decidendi
On the jurisdiction of the Board of Regents and the Special Investigation Committee: The Court affirmed the Solicitor General's submission that the Board of Regents (BOR), as the highest governing body of the university, has the power to create investigating committees to act upon administrative complaints. This authority emanates from Batas Pambansa Blg. 12 (BP Blg. 12), the charter of USP, which grants the BOR general powers of administration and the specific power to appoint deans and other officials. Consonant with the power to hire is the power to discipline. Therefore, the creation of the Special Investigation Committee (SIC) as an arm of the BOR to probe administrative complaints against its officers is within its power of governance. The Court clarified that while Republic Act No. 7722 (RA 7722) transferred jurisdiction over tertiary institutions from the DECS Secretary to the Commission on Higher Education (CHED), it did not remove or curtail the administrative power of the governing boards of state universities. These boards retained jurisdiction over administrative cases involving their officials and employees. The Court also held that BP Blg. 12, a special law governing USP, prevails over the Magna Carta for Public School Teachers (RA 4670), a general law, on matters of composition and jurisdiction of investigating committees. Section 9 of the Magna Carta is silent on the composition of a committee investigating a College Dean, leaving room for the BOR's power under its charter. On the alleged violation of due process and the composition of the SIC: The Court found petitioner's allegations of bias and partiality against Secretary Gloria and the SIC members to be speculative. There was no showing that they had any personal interest in the case. Absent persuasive proof of bias, they are presumed to act regularly in the performance of their official functions and with the "cold neutrality of an impartial judge" implicit in due process. The Court reiterated that the creation of the SIC by the BOR, even with members who were also respondents in a prior Ombudsman case filed by the petitioner, did not automatically violate due process. The petitioner failed to present concrete evidence of bias. On the exhaustion of administrative remedies: The Court stressed that generally, a party must exhaust all available remedies within the administrative arena before seeking judicial relief. This doctrine is based on practical and legal reasons, including lesser expenses and speedier disposition of controversies, and the principle that administrative agencies must be given an opportunity to act and correct errors. Petitioner had no valid reason to block the BOR and the SIC from performing their functions at the outset. Judicial recourse is allowed only after administrative remedies are exhausted. The Court found no merit in petitioner's argument that exhaustion of administrative remedies should not apply because a fair trial was a remote possibility due to the committee's composition, as the alleged bias was speculative. On the passage of B.P. Blg. 12, the repeal of civil service rules and the Magna Carta, and the effect of R.A. 7722: The Court held that BP Blg. 12, a special law governing USP, prevails over the Magna Carta for Public School Teachers (RA 4670), a general law, on matters of composition and jurisdiction of investigating committees. Section 9 of the Magna Carta is silent on the composition of a committee investigating a College Dean, leaving room for the BOR's power under its charter. The Court clarified that while Republic Act No. 7722 (RA 7722) transferred jurisdiction over tertiary institutions from the DECS Secretary to the Commission on Higher Education (CHED), it did not remove or curtail the administrative power of the governing boards of state universities.
Main Doctrine
The Board of Regents of a state university, as the governing body, has the inherent power to create investigating committees to probe administrative complaints against its personnel, and this power is derived from the university's charter, a special law which prevails over general laws like the Magna Carta for Public School Teachers on matters of composition and jurisdiction of such committees. Furthermore, the doctrine of exhaustion of administrative remedies must be complied with before seeking judicial intervention, unless there is a clear showing of grave abuse of discretion or violation of due process.