CUDIA v.

SUPERINTENDENT OF PHILIPPINE MILITARY ACADEMY

G.R. No. 211362
February 24, 2015

FACTS:
Cadet 1CL Aldrin Jeff Cudia was a member of Siklab Diwa Class of 2014 of the PMA. On
November 19, 2013, a Delinquency Report (DR) was issued alleging that Cudia was late for his
ENG412 class five days prior. Cudia claimed to have been dismissed late from his prior OR432
class. However, Maj. Rommel Dennis Hindang, Cudia’s CTO, found that the OR432 professor
never dismissed her class late. On January 7, 2014, Maj. Hindang reported that Cudia had
violated the PMA’s Honor Code for lying.

From January 20-21, 2014, the PMA Honor Committee (HC) held a hearing on Cudia’s honor
violation, the result of which was 8-1 in favor of a guilty verdict. After a chambering session,
Cadet 1CL Dalton John Lagura, the lone dissenter among the voting members, changed his
stance, resulting in a 9-0 guilty verdict. On February 10, 2014, then PMA Supt. Vice Adm. Edgar
Abogado approved Cudia’s dismissal.

Later that month, new PMA Supt. Maj. Gen. Oscar Lopez referred Cudia’s case to the Cadet
Review and Appeals Board (CRAB) for review. On February 28, 2014, Cudia’s parents filed a
complaint before the CHR-CAR alleging human rights violations against him. While the CRAB
upheld Cudia’s dismissal, the CHR issued a resolution holding that Cudia’s human rights were
violated. However, on June 11, 2014, the Office of the President sustained the former and the
AFP Chief of Staff.

ISSUES:
1. Whether the PMA, HC, and CRAB, in dismissing Cudia, committed grave abuse of discretion
by holding that Cudia lied.
2. Whether the CHR investigation carries weight.
3. Whether the PMA's academic freedom authorizes it to impose suitable disciplinary measures
and punishment.

HELD:
1. NO.
Although Cudia was free to leave his OR432 class and proceed to ENG412, he stayed behind to
talk to his professor. Later, he deliberately manipulated the words “class” and “dismiss” to
defend his tardiness. Therefore, Cudia’s intent to deceive in his excuse constitutes a clear honor
violation.

2. NO.
The CHR’s constitutional mandate only extends to the investigation, and not adjudication, of
human rights cases. It can only present recommendations on Cudia’s case, and not settle it.

3. YES.
As an academic institution, the PMA has the right to promulgate rules necessary for the
maintenance of school discipline, in accordance with Section 3(2), Article XIV of the
Constitution. It is within the PMA’s academic freedom to enforce its Honor Code to promote
discipline.