G.R. No. L-79237 October 18, 1988
UNIVERSITY OF SAN CARLOS and VICTINIA A. SATORRE, petitioners, vs. COURT OF APPEALS and JENNIFER C. LEE, respondents.

FACTS

Private respondent Jennifer C. Lee, a student at the University of San Carlos (USC), initially enrolled in Architecture but shifted to Commerce after obtaining failing grades and an incomplete grade in her architecture subjects. Aware that these failing grades would disqualify her from graduating with honors under university policy, she sought to have them changed. Through correspondence with the Ministry of Education, Culture and Sports (MECS), her incomplete grade was changed to a passing grade and her failing grades were changed to “Withdrawn” (W), despite procedural irregularities such as the lack of a supporting class record and the absence of written parental permission for the withdrawal. Subsequently, during the March 28, 1982 graduation, USC conferred upon her a Bachelor of Science in Commerce degree but without honors. Lee then filed an action for mandamus and damages to compel USC to confer the degree cum laude retroactively.

ISSUE

The principal issue is whether mandamus is the proper remedy to compel a university to confer an academic honor. The secondary issue is whether the university’s refusal constituted bad faith warranting an award of damages.

RULING

The Supreme Court ruled in favor of the petitioners, reversing the Court of Appeals. The writ of mandamus is not a proper remedy in this case. Mandamus lies only to compel the performance of a ministerial duty where the plaintiff has a clear legal right to the performance of that duty. The grant of academic honors is not a ministerial act but a discretionary function vested in the educational institution. Schools have the inherent academic freedom to set their own standards and policies for awarding honors. USC’s policy clearly stated that any failing grade disqualifies a student from honors. The Court found that Lee’s change of grades was questionable and achieved through “undue and improper pressure” on MECS authorities, lacking proper documentation. Even with the grade changes, the determination of whether she merited honors remained within the sound discretion of the university. The Court held that petitioners did not commit grave abuse of discretion in denying the honors. Consequently, since Lee had no clear legal right to the honors, her claim for damages necessarily failed. The complaint was dismissed.