May a university revoke an academic degree it has conferred to a graduate who obtained the same through fraud or deceit?

Where it is shown that the conferment of an honor or distinction was obtained through fraud, a university has the right to revoke or withdraw the honor or distinction it has thus conferred. This freedom of a university does not terminate upon the graduation of a student, because it is precisely the graduation of such a student that is in question. Wide indeed is the sphere of autonomy granted to institutions of higher learning, for the constitutional grant of academic freedom is not to be construed in a niggardly manner or in a grudging fashion.

Under the U.P. Charter, the Board of Regents is the highest governing body of the University of the Philippines. It has the power to confer degrees upon the recommendation of the University Council. It follows that if the conferment of a degree is founded on error or fraud, the Board of Regents is also empowered, subject to the observance of due process, to withdraw what it has granted without violating a students rights. An institution of higher learning cannot be powerless if it discovers that an academic degree it has conferred is not rightfully deserved. Nothing can be more objectionable than bestowing a university's highest academic degree upon an individual who has obtained the same through fraud or deceit. The pursuit of academic excellence is the university's concern. It should be empowered, as an act of self-defense, to take measures to protect itself from serious threats to its integrity.

While it is true that the students are entitled to the right to pursue their education, the USC as an educational institution is also entitled to pursue its academic freedom and in the process has the concomitant right to see to it that this freedom is not jeopardized.

In the case at bar, the Board of Regents determined, after due investigation conducted by a committee composed of faculty members from different U.P. units, that private respondent committed no less than ninety (90) instances of intellectual dishonesty in her dissertation. The Board of Regents decision to withdraw private respondents doctorate was based on documents on record including her admission that she committed the offense. (U.P. Board of Regents v. William, G.R. No. 134625, August 31, 1999)