G.R. No. 207412 & G.R. No. 207542; August 7, 2013
Flord Nicson Calawag, Petitioner, vs. University of the Philippines Visayas and Dean Carlos C. Baylon, Respondents. / Micah P. Espia, Jose Marie F. Nasalga and Che Che B. Salcepuedes, Petitioners, vs. Dr. Carlos C. Baylon, Dr. Minda J. Formacion and Dr. Emerlinda Roman (to be substituted by Alfredo E. Pascual, being the new UP President), University of the Philippines Board of Regents, Respondents.

FACTS

The petitioners were graduate students at UP Visayas under a DOST scholarship. After completing their first year, they enrolled in the thesis program, secured a thesis adviser, and formed their thesis committees with the approval of their institute director. They then sought Dean Baylon’s approval for their committee composition and tentative thesis titles as required by the Graduate Program Manual. Dean Baylon disapproved the committees and topics, finding the titles inappropriate for a Fisheries Biology degree as they suggested a historical/social study. He imposed new requirements, including a two-page proposal and the formation of an ad hoc committee to oversee their work.
The petitioners filed a petition for certiorari and mandamus with the RTC, seeking to compel the Dean’s approval and requesting a writ of preliminary mandatory injunction. The RTC granted the injunction. The CA, upon review, annulled the RTC’s order. It held that the Dean’s approval was a discretionary supervisory act, not a ministerial duty, and that the matter involved purely academic concerns beyond judicial jurisdiction.

ISSUE

Whether the Court of Appeals erred in annulling the RTC’s grant of a writ of preliminary mandatory injunction, which sought to compel Dean Baylon to approve the petitioners’ thesis committees and titles.

RULING

The Supreme Court denied the petitions and affirmed the CA’s decision. The legal logic rests on the nature of the Dean’s authority and the principle of non-interference in academic matters. While Article 51 of the Graduate Program Manual states the Dean shall approve the thesis committee upon recommendation, this power is not purely ministerial. The Court applied the doctrine of necessary implication, holding that the power to approve inherently includes the power to disapprove based on valid academic grounds. The Dean, as an academic administrator, possesses supervisory discretion to ensure the thesis aligns with the program’s standards and objectives.
The Court emphasized that academic freedom grants educational institutions, through their officials, the primary authority to set academic standards, evaluate student qualifications, and determine the content and methodology of courses and research. Judicial review is limited to instances of grave abuse of discretion, arbitrariness, or violation of constitutional rights. Here, the Dean’s actions—questioning the relevance of the proposed topics and requiring further elaboration—were exercises of academic judgment to maintain program integrity. The petitioners failed to demonstrate a clear and unmistakable right to compel approval, as their right to education does not equate to a right to dictate specific academic requirements or bypass institutional evaluation processes. Thus, the RTC improperly issued the writ of preliminary mandatory injunction.