ASG Law

Tag: Educational Standards

  • Upholding CHED’s Authority: Ensuring Quality in Higher Education through Closure Orders

    In a significant ruling, the Supreme Court affirmed the Commission on Higher Education’s (CHED) authority to issue closure orders against educational institutions failing to meet required standards. The decision in Mandaue City College vs. CHED underscores CHED’s critical role in safeguarding the quality of higher education in the Philippines. This case clarifies that CHED possesses the power to enforce compliance with educational standards, ensuring that degrees conferred hold legitimate value and protect students from institutions operating without proper authorization.

    Can CHED Shutter a School? Legal Battle Over Mandaue City College Closure

    The legal saga began with the establishment of Mandaue City College (MCC) through a city ordinance. Internal disputes led to a split, resulting in two factions operating independently: one under Dr. Cañete (MCC-Cañete) and another under Dr. Cabahug (MCC-Cabahug). CHED investigated the situation and found that neither school had the proper mandate to offer higher education programs. Consequently, CHED issued cease and desist orders. While MCC-Cabahug complied and gained authorization, MCC-Cañete did not, leading to a Closure Order from CHED and a subsequent Notice to the Public stating that MCC-Cañete lacked legal standing to operate. This prompted MCC-Cañete to file a petition seeking to nullify CHED’s actions, arguing that CHED exceeded its authority.

    At the heart of the controversy was the extent of CHED’s power over higher education institutions, particularly the interpretation of Republic Act No. 7722 (RA 7722), or the Higher Education Act of 1994. MCC-Cañete argued that CHED’s role in school closures was merely recommendatory, while CHED asserted its authority to enforce closure orders to maintain educational standards. The Regional Trial Court (RTC) sided with CHED, a decision that was later upheld by the Court of Appeals (CA). The CA emphasized that allowing schools to operate without proper regulation would undermine the quality of education. This prompted MCC-Cañete to elevate the matter to the Supreme Court.

    The Supreme Court’s analysis centered on RA 7722, specifically Section 8, which outlines CHED’s powers and functions. This section empowers CHED to:

    Section 8. Powers and Functions of the Commission. — The Commission shall have the following powers and functions:

    (e) monitor and evaluate the performance of programs and institutions of higher learning for appropriate incentives as well as the imposition of sanctions such as, but not limited to, diminution or withdrawal of subsidy, recommendation on the downgrading or withdrawal of accreditation, program termination or school closure;

    The Court interpreted this provision as granting CHED the authority to directly impose sanctions, including school closures, to ensure compliance with educational standards. The Supreme Court also highlighted Section 16 of RA 7722, which further empowers CHED to take necessary actions to effectively carry out its functions and attain its objectives.

    SECTION 16 Authority. — The Commission shall exercise such authority as may be deemed necessary within its premises or areas of operation to effectively carry out its powers and functions and to attain its objectives: Provided, That the Commission may seek the assistance of other government agencies for the proper implementation of this Act.

    Building on this principle, the Court addressed MCC-Cañete’s claim that it was exempt from CHED’s regulations due to its establishment under a city ordinance. The Court found that MCC-Cañete’s operation lacked a proper mandate from the legitimate MCC Board, effectively operating as a “rogue school.” This distinction was crucial, as it determined whether MCC-Cañete could claim automatic recognition under Batas Pambansa Bilang 232 (BP 232), the Education Act of 1982.

    The Court refuted MCC-Cañete’s reliance on Section 27 of BP 232, which states that government-operated schools receive automatic recognition upon establishment. The court reasoned that MCC-Cañete was not the MCC recognized by the city ordinance, primarily because Dr. Cañete’s authority had been revoked by the legitimate MCC Board. Without this foundational legitimacy, MCC-Cañete could not claim the benefits of automatic recognition. Further, the Court emphasized that the City of Mandaue disowned the MCC operated by Dr. Cañete.

    The Supreme Court emphasized the importance of upholding CHED’s decisions regarding educational standards. Absent any compelling reason, courts should not substitute their judgment for that of CHED, which possesses specialized knowledge and expertise in regulating higher education institutions. This approach aligns with the principle of administrative deference, recognizing the expertise of administrative agencies in their respective fields.

    The Supreme Court’s decision underscores the necessity of maintaining quality control in higher education. By affirming CHED’s authority to issue closure orders, the Court sent a clear message: institutions must adhere to established standards to protect the interests of students and the integrity of the educational system. This ruling ensures that degrees conferred by higher education institutions hold legitimate value and reflect a commitment to quality education.

    FAQs

    What was the key issue in this case? The primary issue was whether CHED had the authority to issue a closure order against Mandaue City College (MCC-Cañete) for failing to comply with higher education standards. MCC-Cañete argued that CHED’s power was merely recommendatory.
    What did the Supreme Court decide? The Supreme Court upheld CHED’s authority to issue closure orders, affirming the decisions of the lower courts. The Court found that CHED’s power extended beyond mere recommendation.
    Why did CHED issue a closure order against MCC-Cañete? CHED issued the closure order because MCC-Cañete failed to comply with the requirements and rectify the deficiencies found in its programs. This non-compliance prompted CHED to take action.
    What was MCC-Cañete’s main argument against the closure order? MCC-Cañete argued that CHED only had recommendatory powers regarding school closures. They also claimed they were exempt from CHED’s requirements due to being established by a city ordinance.
    How did the Court address MCC-Cañete’s claim of automatic recognition? The Court found that MCC-Cañete was not the same entity as the MCC established by the city ordinance, as its operation lacked a proper mandate. Therefore, it could not claim automatic recognition.
    What is the significance of RA 7722 in this case? RA 7722, the Higher Education Act of 1994, defines CHED’s powers and functions, including the authority to monitor and evaluate higher education institutions. The Court interpreted RA 7722 as granting CHED the power to issue closure orders.
    What is the practical implication of this ruling? This ruling reinforces CHED’s role in ensuring quality education and protecting students from institutions operating without proper authorization. It clarifies CHED’s power to enforce compliance with educational standards.
    What was the impact of the internal disputes within Mandaue City College? The internal disputes led to a split in the college, resulting in two factions operating independently. This ultimately contributed to CHED’s investigation and subsequent closure order against MCC-Cañete.

    This case serves as a reminder to educational institutions of the importance of adhering to established standards and regulations. CHED’s role in ensuring quality education is paramount, and the Supreme Court’s decision reinforces its authority to take necessary actions to protect students and maintain the integrity of the educational system.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Mandaue City College vs. CHED, G.R. No. 252063, February 22, 2023

  • Master’s Degree Requirement for College Faculty: Upholding Educational Standards Over Collective Bargaining Agreements

    The Supreme Court affirmed that a Master’s degree is a mandatory requirement for college faculty members, reinforcing the government’s authority to ensure quality education. The Court held that a Collective Bargaining Agreement (CBA) cannot override this requirement, as the pursuit of high educational standards is of public interest. This ruling emphasizes that educational institutions must prioritize qualified educators, and CBAs must align with existing laws and regulations to maintain the integrity of higher education.

    Whose Rules Apply? Tenure, CBAs, and the Pursuit of Qualified Professors

    This case revolves around the employment of Raymond A. Son, Raymond S. Antiola, and Wilfredo E. Pollarco, who were full-time professors at the University of Santo Tomas (UST). UST, like other higher education institutions, operates under the regulatory authority of the Commission on Higher Education (CHED). The central conflict emerges from the professors’ lack of the Master’s degree typically required for their positions. Although the university hired them, they were unable to obtain the said degree within the prescribed period. The professors argued that they had acquired tenure by default under the Collective Bargaining Agreement (CBA) with the UST Faculty Union. This CBA provision stated that faculty members serving six consecutive semesters on a full-time basis, despite lacking a master’s degree, could be considered tenured. The critical legal question is whether a CBA can supersede the CHED’s regulations regarding faculty qualifications, particularly the requirement for a Master’s degree.

    The situation was further complicated by CHED Memorandum Order No. 40-08, which mandated the strict implementation of minimum qualifications for faculty members, including the Master’s degree requirement. UST, acting on this memorandum, decided not to renew the appointments of faculty members who had not completed their Master’s degrees. The professors argued that this decision violated their tenurial rights under the CBA. Respondents countered that the CHED Memorandum Order took precedence over the CBA. The Labor Arbiter initially ruled in favor of the professors, upholding the CBA provision. However, the National Labor Relations Commission (NLRC) reversed this decision, aligning with the CHED Memorandum Order, until the Court of Appeals sided with UST, emphasizing the importance of academic freedom and regulatory compliance in education.

    The Supreme Court centered its analysis on the interplay between contractual agreements and regulatory mandates. The Court emphasized that the requirement of a Master’s degree for undergraduate program professors has been in place since 1992 through DECS Order 92. This order, issued under the Education Act of 1982, carries the force and effect of law. The court quoted University of the East v. Pepanio, stating that the masteral degree requirement for tertiary education teachers is reasonable and aligns with public interest. The CBA provision regarding tenure by default was deemed void because it conflicted with the then-existing 1992 Revised Manual of Regulations for Private Schools. The Court highlighted that a void contract produces no civil effect, citing Article 1409 of the Civil Code, which states that contracts with objects contrary to law are void from the beginning.

    Art. 1409. The following contracts are inexistent and void from the beginning:

    (1) Those whose cause, object or purpose is contrary to law, morals, good customs, public order or public policy;

    The Supreme Court then addressed the argument that CHED Memorandum Order No. 40-08 was being applied retroactively. The Court clarified that the memorandum merely reiterated the existing requirement of a masteral degree. Petitioners were found unqualified to teach in UST’s undergraduate programs due to their failure to obtain the said master’s degrees despite having ample time to do so. The Court stated that both parties were, in a way, violating the law. UST was maintaining professors without the mandated masteral degrees, while the professors agreed to be employed despite knowing their lack of qualifications. The Court invoked the doctrine of pari delicto, stating that neither party could seek legal aid from the Court under these circumstances.

    Latin for ‘in equal fault,’ in pari delicto connotes that two or more people are at fault or are guilty of a crime. Neither courts of law nor equity will interpose to grant relief to the parties, when an illegal agreement has been made, and both parties stand in pari delicto. Under the pari delicto doctrine, the parties to a controversy are equally culpable or guilty, they shall have no action against each other, and it shall leave the parties where it finds them. This doctrine finds expression in the maxims “ex dolo malo nonoritur actio” and “in pari delicto potior est conditio defendentis.”

    The Court further emphasized that the minimum requirement of a Master’s degree had been cemented in DECS Order 92, Series of 1992. It was clarified that any inaction from the government to strictly enforce this requirement did not erase the violations committed by educational institutions or the parties involved. The Court dismissed the argument that UST was in estoppel or had waived the application of CHED Memorandum Order No. 40-08 by agreeing to the tenure by default provision in the CBA. Such a waiver, the Court reasoned, would be contrary to law and would prejudice the rights of students and the public, who have a right to expect quality education from qualified personnel. The Supreme Court emphasized its previous rulings in cases like University of the East v. Pepanio and Herrera-Manaois v. St. Scholastica’s College, which affirmed the mandatory nature of these qualifications.

    Building on this principle, the Court explicitly stated that UST’s decision not to renew the professors’ appointments was a valid exercise of academic freedom and management prerogative. Academic freedom, as enshrined in the Constitution, includes the right of educational institutions to determine who may teach and to set standards for their faculty. This extends to the school’s prerogative to set high standards of efficiency for its teachers to fulfill the constitutional mandate of quality education. The Court recognized that protecting the rights of laborers should not lead to the oppression or self-destruction of the employer, highlighting the need for a balanced approach that respects both employee rights and institutional autonomy.

    The practical implications of this ruling are significant for both educational institutions and faculty members. Educational institutions must ensure that their faculty meet the minimum qualifications set by regulatory bodies like CHED. Institutions can’t circumvent these requirements through Collective Bargaining Agreements or other contractual arrangements. Faculty members need to be aware of the qualifications required for their positions and take the necessary steps to meet them. The decision underscores the importance of aligning CBAs with existing laws and regulations, preventing conflicts that could compromise educational standards. Ultimately, this ruling reinforces the state’s authority to regulate and supervise educational institutions to protect the public interest and ensure quality education.

    FAQs

    What was the key issue in this case? The central issue was whether a Collective Bargaining Agreement (CBA) could supersede the Commission on Higher Education’s (CHED) regulations regarding the minimum qualifications for college faculty, specifically the requirement for a Master’s degree.
    What did the Collective Bargaining Agreement (CBA) state? The UST-UST Faculty Union CBA had a provision that allowed faculty members who served six consecutive semesters on a full-time basis to acquire tenure, even if they did not possess the required Master’s degree.
    What did CHED Memorandum Order No. 40-08 mandate? CHED Memorandum Order No. 40-08 directed the strict implementation of minimum qualifications for faculty members in undergraduate programs, including the requirement of possessing a Master’s degree.
    What was the Supreme Court’s ruling? The Supreme Court ruled that the CHED Memorandum Order took precedence over the CBA, meaning that the Master’s degree requirement was mandatory and could not be overridden by a contractual agreement.
    What is the doctrine of pari delicto? The doctrine of pari delicto states that when two parties are equally at fault in an illegal agreement, neither party can seek legal relief from the courts; the courts will leave them as they are. In this case, both the university and the professors were considered at fault – the university for hiring unqualified personnel and the professors for accepting employment without meeting the qualifications.
    What is academic freedom, and how does it apply to this case? Academic freedom is the right of educational institutions to determine for themselves who may teach, what may be taught, how it shall be taught, and who may be admitted to study. In this case, the Court recognized that UST’s decision not to renew the professors’ appointments was a valid exercise of academic freedom.
    What is the significance of DECS Order 92, Series of 1992? DECS Order 92, Series of 1992, also known as the Revised Manual of Regulations for Private Schools, established the minimum qualifications for faculty members, including the requirement of a Master’s degree. This order has the force and effect of law.
    Can faculty members waive the Master’s degree requirement through a CBA? No, the Supreme Court ruled that the Master’s degree requirement cannot be waived through a CBA, as such a waiver would be contrary to law and would prejudice the rights of students and the public to receive quality education from qualified personnel.

    This case underscores the importance of adhering to regulatory standards in the field of education. While collective bargaining agreements provide a framework for labor relations, they cannot undermine the state’s power to ensure quality education through mandated qualifications. Institutions and educators alike must be vigilant in upholding these standards to maintain the integrity of the educational system.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Raymond A. Son, et al. v. University of Santo Tomas, G.R. No. 211273, April 18, 2018

  • Master’s Degree as a Prerequisite for Tenure: University of the East vs. Pepanio and Bueno

    This case clarifies that private schools can require teachers to possess a master’s degree as a condition for attaining regular employment status, reinforcing the institutions’ rights to set academic standards. The Supreme Court emphasized that even if teachers have served for a long period, they are not automatically entitled to tenure if they do not meet the necessary educational qualifications established by the school and regulatory bodies. This ruling underscores the importance of aligning employment conditions with educational policies to ensure quality in educational institutions.

    The Tenure Hurdle: Can Experience Trump Academic Credentials at UE?

    The central question in University of the East v. Pepanio and Bueno revolves around whether the respondents, Analiza F. Pepanio and Mariti D. Bueno, could claim regular employment status at the University of the East (UE) despite lacking the requisite postgraduate degrees. Both teachers were initially hired on a semester-to-semester basis and later given probationary appointments. However, UE declined to grant them tenure because they did not possess master’s degrees, a requirement stipulated in the university’s policies and aligned with national educational standards. This case examines the interplay between contractual agreements, regulatory standards, and the rights of educational institutions to enforce academic qualifications for faculty tenure.

    The narrative begins with the educational qualifications mandated by the Department of Education, Culture and Sports (DECS) in 1992. The Revised Manual of Regulations for Private Schools required college faculty members to hold a master’s degree to achieve regular status. This policy set the stage for subsequent collective bargaining agreements (CBAs) between UE and its faculty association. The 1994 CBA, for instance, allowed UE to offer semester-to-semester appointments to college faculty who did not meet the minimum qualifications. This was followed by DECS-CHED-TESDA-DOLE Joint Order 1 in 1996, which reiterated that academic personnel lacking minimum academic qualifications could not acquire tenure or regular status.

    Against this backdrop, UE hired Mariti D. Bueno in 1997 and Analiza F. Pepanio in 2000, both on a semester-to-semester basis. While Bueno enrolled in some postgraduate courses, she did not complete them. Pepanio accumulated 27 graduate units, but these could no longer be credited due to her failure to continue her studies within the stipulated five-year period. In 2001, a new CBA provided a conditional path to probationary status for faculty members without postgraduate degrees, contingent on their compliance with the requirement during their probationary period. However, UE retained the option to replace these appointees if more qualified teachers became available.

    Pursuant to the new CBA, UE extended probationary appointments to Bueno and Pepanio. The Dean of the UE College of Arts and Sciences, Eleanor Javier, later issued notices reminding probationary faculty members about the impending expiration of their status. Pepanio indicated she was enrolled in graduate school, while Bueno expressed disinterest in pursuing tenure. Subsequently, the school extended their probationary period, but neither Pepanio nor Bueno reported for work. Both then demanded to be recognized as regular employees, citing their years of service on a full-load basis. When UE refused, they filed cases of illegal dismissal.

    In its defense, UE argued that it never considered the respondents as regular employees because they did not meet the master’s degree requirement. The Labor Arbiter (LA), however, initially ruled in favor of Bueno and Pepanio, asserting that they had attained regular status under the old CBA by teaching for at least four semesters. The LA also concluded that the new CBA could not strip them of benefits they had already earned, leading to an order for their reinstatement with backwages. This decision was subsequently appealed by UE to the National Labor Relations Commission (NLRC).

    The NLRC reversed the LA’s decision, rejecting the argument that the four-semester probationary period automatically conferred permanent status. According to the NLRC, Bueno and Pepanio still had to meet the standards for permanent employment outlined in the Manual of Regulations and the Joint Order. The non-renewal of their contracts was justified by their failure to obtain the required postgraduate degrees, thus not constituting illegal dismissal. This reversal led the respondents to file a petition for certiorari with the Court of Appeals (CA).

    The Court of Appeals reinstated the LA’s decision, citing procedural technicalities. The CA held that UE’s appeal to the NLRC was untimely, as it was filed beyond the 10-day period for appeal. The CA calculated the period from the date the postmaster gave notice to UE’s legal counsel to claim the mail containing the LA Decision. UE then filed a petition with the Supreme Court, leading to the present decision. The Supreme Court addressed several critical issues, including the timeliness of UE’s appeal to the NLRC, the absence of a certification from the UE Board of Trustees authorizing the verification and certification of non-forum shopping, and the legality of the alleged dismissal of Bueno and Pepanio.

    Regarding the timeliness of the appeal, the Supreme Court clarified that the reckoning period for completeness of service by registered mail starts either from the date of actual receipt or after five days from the date of the first notice from the postmaster. The critical point is that there must be conclusive proof that the registry notice was received or served. In this case, the absence of proof that Atty. Mison received the registry notice from the post office led the Court to consider the registry return receipt, bearing the date April 4, 2005, as conclusive proof of service. This meant that UE’s appeal to the NLRC was filed on time, overturning the CA’s ruling based on procedural grounds.

    The Court also addressed the issue of the missing Secretary’s Certificate authorizing Dean Javier to sign the verification and certification of non-forum shopping. While the general rule requires such authorization from the Board of Directors or Trustees, the Court acknowledged an exception. Authorization is unnecessary when it is self-evident that the signatory is positioned to verify the truthfulness and correctness of the allegations in the petition. The Court found that Dean Javier, based on the facts of the case, was indeed in such a position. Therefore, the petition was not dismissed on this procedural technicality either.

    Finally, the Court turned to the substantive issue of whether UE had illegally dismissed Bueno and Pepanio. The respondents argued that they were hired when the 1994 CBA was in force, which they claimed did not require a master’s degree for acquiring regular status. They asserted that they had met the requirements of full-time service, three consecutive years of service, and satisfactory performance, thus entitling them to permanent status. However, the Court pointed out that the policy requiring postgraduate degrees for college teachers had been in place since the 1992 Manual of Regulations.

    Moreover, the Court emphasized that a school’s CBA must be read in conjunction with statutory and administrative regulations governing faculty qualifications. As the Court held in Escorpizo v. University of Baguio:

    a school CBA must be read in conjunction with statutory and administrative regulations governing faculty qualifications. Such regulations form part of a valid CBA without need for the parties to make express reference to it. While the contracting parties may establish such stipulations, clauses, terms and conditions, as they may see fit, the right to contract is still subject to the limitation that the agreement must not be contrary to law or public policy.

    The Court further explained that the State, through Batas Pambansa Bilang 232 (The Education Act of 1982), had delegated the administration of the education system to the Ministry of Education, Culture and Sports (now the Department of Education). This delegation included the power to regulate educational institutions and prescribe minimum academic qualifications for teaching personnel. The requirement of a masteral degree for tertiary education teachers was deemed reasonable, given the public interest involved in the operation of educational institutions.

    The Court noted that the respondents were given only semester-to-semester appointments precisely because they lacked the required master’s degree. It was only with the 2001 CBA that the school extended a conditional probationary status, contingent on obtaining a master’s degree. The Court concluded that the parties clearly intended to subject the respondents’ permanent status appointments to the standards set by law and university policy. UE had provided ample opportunities for Bueno and Pepanio to acquire the necessary postgraduate degrees, but they did not take advantage of them. Therefore, the Court held that it would be unjust to penalize the employer for a situation in which they had little or no control.

    The Supreme Court, in granting the petition, emphasized the importance of upholding educational standards and the rights of educational institutions to enforce academic qualifications. The Court reversed the CA’s decision and reinstated the NLRC’s decision, which had dismissed the complaints of Analiza F. Pepanio and Mariti D. Bueno. This decision underscores that the attainment of tenure in educational institutions is not solely based on years of service but also on meeting the prescribed academic qualifications mandated by law and institutional policies. It reinforces the principle that contractual agreements must align with public policy and regulatory requirements to ensure quality education.

    FAQs

    What was the key issue in this case? The primary issue was whether teachers lacking a master’s degree could claim regular employment status based on years of service, despite the university’s policy requiring such a degree for tenure. The court also addressed procedural issues regarding the timeliness of the appeal and the required authorization for verification and certification.
    What did the Court decide regarding the master’s degree requirement? The Supreme Court upheld the university’s right to require a master’s degree as a condition for tenure, even if the teachers had served for a significant period. The Court emphasized that regulatory standards and public policy support this requirement to ensure quality education.
    Why did the Court reverse the Court of Appeals’ decision? The Court of Appeals had ruled in favor of the teachers based on procedural technicalities, specifically the timeliness of the university’s appeal. The Supreme Court found that the appeal was indeed timely, and it addressed the substantive issue of the master’s degree requirement.
    What is the significance of the Escorpizo v. University of Baguio case? The Escorpizo case, cited by the Court, established that collective bargaining agreements (CBAs) in schools must be read in conjunction with statutory and administrative regulations governing faculty qualifications. This means that CBAs cannot override legal and regulatory requirements.
    What was the role of the Collective Bargaining Agreement (CBA) in this case? The CBA outlined the terms of employment, including the conditions under which teachers could attain probationary and regular status. However, the Court clarified that the CBA could not supersede the requirement of a master’s degree as mandated by law and university policy.
    What are the implications for private schools in the Philippines? The ruling confirms that private schools have the right to enforce academic qualifications for faculty tenure, aligning with national educational standards. This helps to ensure the quality of education provided by these institutions.
    Did the teachers have any opportunities to meet the master’s degree requirement? Yes, the University of the East provided opportunities for the teachers to obtain a master’s degree, including extending probationary status conditional on them meeting the requirement. The Court noted that the teachers did not adequately take advantage of these opportunities.
    What is the effect of the ruling on the teachers involved in the case? The Supreme Court reinstated the NLRC’s decision, which had dismissed the teachers’ complaints of illegal dismissal. This means they were not entitled to reinstatement or backwages, as they did not meet the requirements for regular employment.

    In conclusion, this case reinforces the principle that educational institutions have the right to set and enforce academic standards for their faculty, ensuring quality education. The Supreme Court’s decision emphasizes that tenure is not solely based on length of service but also on meeting required qualifications.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: University of the East, G.R. No. 193897, January 23, 2013