G.R. No. 134625. August 31, 1999 (Case Brief / Digest)

### Title: University of the Philippines Board of Regents vs. Hon. Court of Appeals and Arokiaswamy William Margaret Celine

### Facts:

Arokiaswamy William Margaret Celine, a citizen of India and holder of a Philippine visitor’s visa, enrolled in the doctoral program in Anthropology at the University of the Philippines College of Social Sciences and Philosophy (CSSP) in April 1988. After completing her coursework, she took a two-year leave to work abroad before returning to the Philippines to work on her dissertation titled “Tamil Influences in Malaysia, Indonesia, and the Philippines.” On December 22, 1992, the U.P. Department of Anthropology certified that Celine had finished her dissertation and scheduled her oral defense. However, it was discovered that parts of her dissertation were plagiarized from various sources. Despite this, she defended her dissertation and obtained majority approval from the panel.

The CSSP College Faculty Assembly tentatively approved Celine’s graduation pending final dissertation submission. Nevertheless, after submitting her revised dissertation in April 1993, not all panel members approved it due to unresolved plagiarism concerns. Celine was included in the list of candidates for graduation, but Dean Paz later requested her exclusion due to unresolved issues surrounding her dissertation. Despite this, the Board of Regents approved the graduation list including Celine, who subsequently graduated with her Ph.D. in Anthropology.

Following her graduation, allegations of plagiarism led to an investigation by an ad hoc committee, which found substantial evidence of plagiarism in Celine’s dissertation. This led to a recommendation to withdraw her Ph.D. degree, eventually endorsed by the University Council and the Board of Regents after a series of investigations and committee reviews, including one by a special committee chaired by Dr. Paulino B. Zafaralla.

Celine appealed the decision to withdraw her degree through various channels within the university and through the Commission on Human Rights and the Board of Regents, citing due process concerns and the lack of authority to withdraw a conferred degree. After her appeals were unfruitful, she filed a petition for mandamus with the Regional Trial Court of Quezon City, which was initially dismissed. However, the Court of Appeals later reversed this decision, ordering the restoration of her Ph.D. degree. This led the University of the Philippines Board of Regents to appeal to the Supreme Court.

### Issues:

1. Whether the writ of mandamus is applicable to compel the University of the Philippines to restore Celine’s doctoral degree.
2. Whether the withdrawal of Celine’s doctoral degree violated her right to enjoyment of intellectual property and to justice and equity.
3. Whether the procedure followed by the University of the Philippines in withdrawing Celine’s doctoral degree violated her right to substantive due process.

### Court’s Decision:

The Supreme Court reversed the Court of Appeals’ decision, holding that the University of the Philippines did not violate Celine’s right to substantive due process. The university had provided her with ample opportunity to defend herself against the plagiarism charges through various investigation committees. The court underscored the university’s authority to confer and, by implication, withdraw degrees based on academic dishonesty. It emphasized academic freedom and the autonomy of educational institutions to maintain academic standards and integrity.

The Supreme Court found that Celine was afforded due process, had the opportunity to respond to the plagiarism charges, and could not prove her entitlement to the restoration of her degree via mandamus. The issuing of her degree, if based on fraud or misrepresentation, can be reconsidered and withdrawn by the university.

### Doctrine:

The doctrine established in this case emphasizes the academic freedom of educational institutions to confer, and subsequently withdraw, degrees obtained through fraud or dishonesty. It underscores the principle that due process in administrative proceedings, particularly in academic institutions, is satisfied by providing the respondent an opportunity to be heard and to defend against the charges.

### Class Notes:

– **Academic Freedom:** Universities have the autonomy to determine academic standards, including the conferment and withdrawal of degrees.
– **Due Process in Academic Settings:** Does not necessitate a trial-type proceeding but requires notification of charges and an opportunity to respond.
– **Mandamus:** Not applicable for compelling academic institutions to confer or restore degrees unless there is a clear legal duty to act.
– **Investigation of Plagiarism:** Institutions may set up committees to investigate academic dishonesty, whose findings can affect conferred degrees.
– **Withdrawal of Degrees:** Degrees obtained through dishonesty, such as plagiarism, can be withdrawn to protect academic integrity.

### Historical Background:

This case illustrates the legal challenges surrounding academic dishonesty and the balance between the rights of students and the autonomy of educational institutions to uphold academic standards. It highlights the procedural nuances in administrative inquiries within academic settings and reaffirms the principle of academic freedom as a cornerstone in higher education jurisprudence in the Philippines.


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