USC and Satorre v. CA and Lee G.R. No.

79237

Facts: Jennifer Lee was a student of USC. She first enrolled in the College of
Architecture, but has failed 2 subjects. When she transferred to the College of
Commerce, she made good grades. The university disqualified her from graduating
with honors taking into consideration, as part of the university policy, her failing
grades in the College of Architecture. She filed an action for mandamus with
damages against petitioners in the Cebu RTC, asking that the latter be compelled to
confer upon her the degree of B.S. Commerce, major in Accounting, cum laude.
Petitioners allege that it may not be compelled to grant graduation honors to
students who, according to university standards, rules, and regulations, do not
qualify for such honors.

Issue: whether or not petitioners may be compelled to grant graduation honors to

Jennifer Lee.

Ruling: NO. It is an accepted principle that schools given ample discretion to

formulate rules and guidelines in the granting of honors for purposes of graduation.
This is part of academic freedom. Within the parameters of these rules, it is within
the competence of universities and colleges to determine who are entitled to the
grant of honors among the graduating students. Its discretion on this academic
matter may not be disturbed much less controlled by the courts unless there is
grave abuse of discretion in its exercise. In this case, the petitioner's bulletin of
information provides all students and all other interested parties advice on the
University policies and rules on enrollment and academic achievements. A failure in
any subject disqualifies a student from honors. Good moral character and
exemplary conduct are as important criteria for honors as academic achievements.
Private respondent should know and is presumed to know those University policies
and is bound to comply therewith.