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    Camacho vs. Gloria

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    Gia Dimayuga
    The document summarizes the case of Dr. Manuel Camacho vs. Hon. Ricardo Gloria (2003) regarding the doctrine of exhaustion of administrative remedies. [1] Camacho filed complaints against decisions upholding grades given to absent students. [2] An administrative case was filed against Camacho. [3] The court held that the Board of Regents had jurisdiction over the case against Camacho and forming the investigation committee did not violate his right to due process, as he did not show proof of bias.

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    Camacho vs. Gloria

    Uploaded by

    Gia Dimayuga
    135 views2 pages
    The document summarizes the case of Dr. Manuel Camacho vs. Hon. Ricardo Gloria (2003) regarding the doctrine of exhaustion of administrative remedies. [1] Camacho filed complaints against decisions upholding grades given to absent students. [2] An administrative case was filed against Camacho. [3] The court held that the Board of Regents had jurisdiction over the case against Camacho and forming the investigation committee did not violate his right to due process, as he did not show proof of bias.

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    The document summarizes the case of Dr. Manuel Camacho vs. Hon. Ricardo Gloria (2003) regarding the doctrine of exhaustion of administrative remedies. [1] Camacho filed complaints against decisions upholding grades given to absent students. [2] An administrative case was filed against Camacho. [3] The court held that the Board of Regents had jurisdiction over the case against Camacho and forming the investigation committee did not violate his right to due process, as he did not show proof of bias.

    Copyright:

    © All Rights Reserved
    135 views2 pages

    Camacho vs. Gloria

    Uploaded by

    Gia Dimayuga
    The document summarizes the case of Dr. Manuel Camacho vs. Hon. Ricardo Gloria (2003) regarding the doctrine of exhaustion of administrative remedies. [1] Camacho filed complaints against decisions upholding grades given to absent students. [2] An administrative case was filed against Camacho. [3] The court held that the Board of Regents had jurisdiction over the case against Camacho and forming the investigation committee did not violate his right to due process, as he did not show proof of bias.

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    Dr. Manuel Camacho vs. Hon.

    Ricardo Gloria (2003)

    Due Process - Doctrine of Exhaustion of Administrative Remedies

    FACTS

    Camacho is the Dean of the College of Education of the University of Southeastern


    Philippines (USP), a State University. Doctorate Students complained to him about the passing
    grades that Dr. Daleon gave to ghost students who failed to attend classes.

    Camacho brought the matter to the Board of Regents (BOR) where Department of
    Education, Culture and Sports (DECS) Secretary Ricardo Gloria sat as chairman. The BOR
    upheld the grade given by Dr. Daleon. Disgruntled, petitioner filed a complaint against Dr.
    Daleon before the Office of the Ombudsman for gross incompetence and insubordination. The
    complaint, and was later amended to include the University Board of Regents chaired by then
    DECS Secretary Gloria, DECS Legal Officer Reno Capinpin, and the three students who
    received passing marks despite numerous absences.

    Meanwhile, on February 21, 1996, Dr. Thelma S. Ledesma, Secretary of the Board of
    Regents of USP, filed an Administrative Case against petitioner before the Office of the USP
    President for grave misconduct, conduct unbecoming of a dean and falsification of public
    documents. Ledesma alleged that petitioner rigged the results of the performance evaluation
    test taken by her students in order to justify Camacho in not giving them any teaching
    assignment.

    Secretary Gloria, in his capacity as Chairman of the Board of Regents of USP, created a
    Special Investigation Committee (SIC). Camacho moved for the inhibition of the committee
    members on the ground that the ones who formed the committee, namely DECS Secretary
    Gloria and the committee chairman, Atty. Capinpin, were both respondents in the Ombudsman
    case he filed. Petitioner prayed that the Special Investigation Committee be restrained from
    hearing Admin. Case as the creation of the committee violated his right to due process.

    ISSUES

    1. Whether or not the Board of Regents of USP, through the Special Investigation
    Committee, has jurisdiction over the Adm. Case against Camacho? –YES, BOR has
    jurisdiction

    2. Whether or not Camacho’s right to due process was violated by the Special
    Investigation Committee of the university? –NO, did not violate right to due process /
    right to due process was not infringed by the BOR’s formation of the Special
    Investigation Committee.
    HELD

    1. The Board of Regents where DECS Secretary Gloria sat as Chairman has jurisdiction
    over the administrative case filed by Dr. Ledesma against petitioner. The BORs authority
    to create the investigating committee as its arm to probe into the charges against
    petitioner emanates from the law creating USP, its Charter, BP Blg. 12.Section 6
    provides that the governing body of the university shall be the Board of Regents. In
    addition to its general powers of administration, the Charter also accords the Board the
    specific power to appoint the deans, directors, or heads of colleges, schools, institutes
    and other principal units of the university. Consonant to its power to hire is the power
    to discipline its personnel. It is, therefore, in line with the BORs power of governance
    to create a Special Investigation Committee to probe into administrative complaints filed
    against its officers.

    2. Camacho’s allegations that Secretary Gloria and the Special Investigation Committee
    members were biased and partial are merely speculative. There is no showing that the
    Education Secretary and the Committee members had an interest, personal or
    otherwise, in the prosecution of the case against petitioner. Absent persuasive proof of
    bias and partiality, Secretary Gloria and the committee could not be presumed to be
    incapable of acting regularly in the performance of official functions. They must be
    accorded the benefit of the presumption that they would act in a manner befitting their
    sworn duties, particularly, with the cold neutrality of an impartial judge implicit in the
    guarantee of due process.

    Doctrine of Exhaustion of Administrative Remedies/Principle of Exhaustion

    Generally, a party must explore all remedies available in the administrative arena
    before seeking judicial relief. This doctrine of exhaustion of administrative remedies is
    not without its practical and legal reasons. For one thing, availment of administrative
    remedy entails lesser expenses and provides for a speedier disposition of controversies.
    The administrative authority must be given an opportunity to act and correct the errors
    committed in the administrative forum. In this case, petitioner has no valid reason to
    block at the very outset the Board of Regents and the Special Investigation Committee
    from performing their functions. Only after administrative remedies are exhausted may
    judicial recourse be allowed

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