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Did the Ombudsman investigator committed grave abuse of discretion in dismissing the administrative complaint against a faculty member who gave passing grades to certain students without requiring them to attend classes?


We agree with respondents position on the primacy of academic freedom in regard to higher institutions of learning. Dr. Daleons teaching style, validated by the action of the USP Board of Regents, is bolstered by the constitutional guarantee on academic freedom. Academic freedom is two-tiered that of the academic institution and the teachers.

Institutional academic freedom includes the right of the school or college to decide for itself, its aims and objectives and the methods on how best to attain them, free from outside coercion or interference save possibly when the overriding public welfare calls for some restraint. It encompasses the freedom to determine for itself on academic grounds: who may teach, what may be taught, how it shall be taught, and who may be admitted to study. The right of the school to confirm and validate the teaching method of Dr. Daleon is at once apparent in the third freedom, i.e., how it shall be taught.

Academic freedom also accords a faculty member the right to pursue his studies in his particular specialty. It is defined as a right claimed by the accredited educator, as teacher and as investigator, to interpret his findings and to communicate his conclusions without being subjected to any interference, molestation, or penalty because these conclusions are unacceptable to some constituted authority within or beyond the institution. As applied to the case at bar, academic freedom clothes Dr. Daleon with the widest latitude to innovate and experiment on the method of teaching which is most fitting to his students (graduate students at that), subject only to the rules and policies of the university. Considering that the Board of Regents, whose task is to lay down school rules and policies of the University of Southeastern Philippines, has validated his teaching style, we see no reason for petitioner to complain before us simply because he holds a contrary opinion on the matter. (Camacho v. Coresis, G.R. No. 134372, August 22, 2002)

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