GR 161172; (December, 2004) (Digest)
G.R. No. 161172, December 13, 2004
NADINE ROSARIO M. MORALES, petitioner, vs. THE BOARD OF REGENTS OF THE UNIVERSITY OF THE PHILIPPINES, respondent.
FACTS
Petitioner Nadine Rosario M. Morales transferred to the University of the Philippines (UP) Diliman, enrolling in the European Languages program under the Plan A curriculum with a major in French and an initial minor in German. She obtained grades of 1.0 in German 10 and 11. She later changed her minor to Spanish. Based on computations including her German grades, her college listed her as a candidate for graduation “with probable honors,” as her General Weighted Average (GWA) was above the 1.75 required for cum laude.
During the final graduation assessment, UP excluded her German 10 and 11 grades from her GWA computation. The University held that under her Plan A curriculum with a Spanish minor, German courses did not qualify as valid electives, as the curriculum required electives to be in the major language or the approved minor. This exclusion lowered her GWA to 1.760, disqualifying her for honors. Petitioner’s appeals to the University Council and the UP Board of Regents were denied.
ISSUE
Whether the University of the Philippines committed grave abuse of discretion in excluding petitioner’s German grades from the computation of her General Weighted Average for honors.
RULING
The Supreme Court ruled that UP did not commit grave abuse of discretion. The Court emphasized the doctrine of academic freedom, which grants educational institutions ample discretion to formulate and implement academic rules, including those for granting honors. The interpretation and application of such internal rules are primarily vested in the university authorities.
The legal logic is that courts will not interfere in academic decisions absent a clear showing of grave abuse of discretion, which implies a capricious, arbitrary, or whimsical exercise of judgment equivalent to lack of jurisdiction. Here, UP’s exclusion of the German grades was based on a reasonable interpretation of its own Code (Article 410) and the specific requirements of the Plan A curriculum. The University consistently maintained that for a student under Plan A, electives must align with the major or the officially declared minor. Since petitioner ultimately minored in Spanish, her basic German language courses were not considered qualifying electives under the governing rules. The University’s decision was reached through deliberative processes, including reviews by the Department, College, University Council, and the Board of Regents. Thus, there was no arbitrariness, and the Court found no ground to substitute its judgment for the academic expertise of the University. The petition was denied.