University of San Carlos (USC) v. Court of Appeals (CA) | G.R. No. L-79237 | October 18, 1988 | J. Guncayco
| Article XIV – Section 5 |
Petitioners: University of San Carlos and Victoria A. Satorre
Respondents: Court of Appeals and Jennifer C. Lee
Recit Ready Summary:
[FREEDOM TO GIVE HONORS] Jennifer Lee was enrolled in the College of Architecture of the University of San Carlos. At the end of the
second semester she obtained a grade of “IC (incomplete)” and two failing marks. She then shifted to the
College of Commerce the next year. Knowing that her earlier failing marks would be taken into consideration
to determine if she could graduate w/ honors, she wrote to the Council of Deans and to the Ministry of
Education, Culture and Sports (MECS) requesting that her failing marks be disregarded in the computation
of her average grade. When the USC President was out of town, she requested the USC Registrar to
change her failing grades. When the request was referred to the MECS, such was approved. Lee graduated
with the degree in Commerce, still without honors.
Lee filed a case before the RTC to compel petitioners to confer upon her the degree of BS in Commerce,
major in Accounting, cum laude. RTC and CA ruled in her favor. Petitioners now come before the Court
contending that a university may not be compelled to grant graduation honors to any students who,
according to the university’s standards, rules and regulations, does not qualify for such honors.
HELD: As part of academic freedom, schools of learning are given ample discretion to formulate rules
and guidelines in the granting of honors for purposes of graduation. USC’s policies and rules on
enrollment and academic achievement provide that:
- A student may NOT officially withdraw from subjects if he does not have the written permission
of his parents or guardian.
- For an incomplete grade, there must be an application for completion or removal within the
period announced by the school calendar and when not removed within 1 year, it automatically
becomes final.
- A failure in any subject disqualifies a student from honors.
In the present case, the change of the “IC” grade was not made within one year. Thus, it became final
according to the rules. Moreover, the change of Lee’s failing grades to “W (withdrawn)” was without the
written permission of her parents or guardian. The court ruled that the petitioners did not commit grave
abuse of discretion in denying the honors sought by Lee. Also, even if Lee succeeded in removing her failing
grades, it was still within the sound discretion of USC to determine whether she was entitled to graduate with
honors.
FACTS
1. Jennifer Lee enrolled in the College of Architecture, University of San Carlos. At the end of the second
semester she obtained the following grades:
- A grade of “I.C.” (incomplete)
- Two failing marks
2. The following school year, she shifted to the College of Commerce of the USC. As a commerce student,
she obtained good grades.
3. She was aware of her earlier failing grades in the College of Architecture and that they would be taken
into consideration in the evaluation of her overall academic performance to determine if she could
graduate with honors.
4. She wrote to the Council of Deans of the USC requesting that her failing marks be disregarded in the
computation of her grade average. She also wrote a similar letter to the Ministry of Education, Culture
and Sports (MECS).
5. The letter was referred to the USC President for comment. The President informed MECS about the
university’s policy that any failing grade obtained by a student in any course would disqualify a student
for honors.
6. When the USC President was out of town, Jennifer Lee wrote to the USC Registrar requesting that her
failing grades be changed.
7. The USC Registrar referred her letter to the MECS. The request was approved.
- Her grade of “I.C.” was changed to 1.9
- Failing grades were changed to W (withdrawn)
8. Bacalso of MECS’ Higher Education Division discovered that the change of grade from “I.C.” to 1.9 did
not have the supporting class record required. He wrote to the MECS Supervisor requesting the
submission of such class record.
9. USC held its graduation exercises and Jennifer Lee graduated with the degree of Bachelor of Science in
Commerce, Major in Accounting, WITHOUT HONORS.
10. Dean Satorre explained that the matter was held in abeyance pending compliance with the required
class records.
11. Jennifer Lee filed an action for mandamus with damages against USC and Dean Satorre, asking that
petitioners be compelled to confer upon her the degree of BS in Commerce, Major in Accounting, cum
laude.
12. Judgment was rendered in her favor. Petitioners appealed to the CA. But the CA affirmed the lower
court’s decision.
13. Hence, this petition. Petitioners allege that a university may not be compelled to grant graduation honors
to any students who, according to the university’s standards, rules and regulations, does not qualify for
such honors.
ISSUE: Whether or not university may be compelled to confer a degree with honors? No
HELD:
1. Schools of learning are given ample discretion to formulate rules and guidelines in the granting
of honors for purposes of graduation. This is part of academic freedom. Its discretion on this
academic matter may not be disturbed or controlled by the courts unless there is grave abuse of
discretion in its exercise.
2. In the case at bar, petitioners did not commit grave abuse of discretion in denying the honors sough by
private respondent under the circumstances.
3. USC’s bulletin of information provides all students and all other interested parties advise on the
University policies and rules on enrollment and academic achievements. It is provided that:
- A student may NOT officially withdraw from subjects in the curriculum if he does not have the
written permission of his parents or guardian.
- For an incomplete grade, there must be an application for completion or removal within the
period announced by the school calendar and when not removed within 1 year, it automatically
becomes final.
- A failure in any subject disqualifies a student from honors.
4. Jennifer Lee is presumed to now these University policies and is bound to comply with them.
5. The change in Lee’s grade from “IC” to “1.9” was not supported by the required class records. Moreover,
the change was not made within one year. Thus, the “INC” grade became final according to the rules.
6. The change of Lee’s failing grades to “W (withdrawn)” was without the written permission of her parents
or guardian. It was also unusual that a student who got a failing mark should still be allowed to withdraw
from such subject.
7. Obviously, Lee employed undue and improper pressure on the MECS authorities to approve the change
of her grades to remove all obstacles to her graduation.
8. Even if Lee succeeded in removing her failing grades, it was still within the sound discretion of USC to
determine whether she was entitled to graduate with honors.
DISPOSITION: Granted. CA decision reversed
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