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A. Academic Freedom

1. ACADEMIC FREEDOM IN HIGHER LEARNING

a. Concept

Academic freedom shall be enjoyed in all institutions of higher learning. (Section 5[2], Article XIV, 1987 Constitution)

A school enjoys academic freedom – a guarantee that enjoys protection from the Constitution no less. Section 5(2) Article XIV of the Constitution guarantees all institutions of higher learning academic freedom. (Mercado v. AMA Computer College-Parañaque City, Inc., G.R. No. 183572, 13 April 2010)

1) Power to adopt and enforce rules

An educational institution has the power to adopt and enforce such rules as may be deemed expedient for its government, this being incident to the very object of incorporation, and indispensable to the successful management of the college. It can decide for itself its aims and objectives and how best to attain them, free from outside coercion or interference except when there is an overriding public welfare which would call for some restraint. (Cudia v. The Superintendent of the Philippine Military Academy [PMA], En Banc, G.R. No. 211362, 24 February 2015)

a) A privilege with limitations

Academic freedom has never been meant to be an unabridged license. It is a privilege that assumes a correlative duty to exercise it responsibly. An equally telling precept is a long recognized mandate, so well expressed in Article 19 of the Civil Code, that every “person must, in the exercise of his rights and in the performance of his duties, act with justice, give everyone his due, and observe honesty and good faith.” (Ibid.)

b) Includes power to grant honors or not

The discretion of schools of learning to formulate rules and guidelines in the granting of honors for purposes of graduation forms part of academic freedom. And such discretion may not be disturbed much less controlled by the courts, unless there is grave abuse of discretion in its exercise. Therefore, absent any showing of grave abuse of discretion, the courts may not disturb the University’s decision not to confer honors to a student. (Morales v. The Board of Regents of the University of the Philippines, G.R. No. 161172, 13 December 2004)

2) Granted to higher learning, public or private

Pursuant to paragraph 2, Section 5 of Article XIV of the Constitution of the Republic of the Philippines, all institutions of higher learning, public or private, shall enjoy academic freedom and institutional autonomy. (Section 11, R.A. 8292)

Academic freedom is the institutional autonomy of universities and institutions of higher learning. (Cudia v. The Superintendent of the Philippine Military Academy [PMA], En Banc, G.R. No. 211362, 24 February 2015)

3) When CHED may intervene

GENERAL RULE: Nothing in R.A. 7722 or the Higher Education Act of 1994 shall be construed as limiting the academic freedom of universities and colleges. In particular, no abridgment of curricular freedom of the individual educational institutions by the Commission on Higher Education (CHED) shall be made. (Section 13, R.A. 7722)

EXCEPTIONS:

1) Minimum unit requirements for specific academic programs;

2) General education distribution requirements as may be determined by the Commission; and

3) Specific professional subjects as may be stipulated by the various licensing entities.  (Ibid.)

No academic or curricular restriction shall be made upon private educational institutions which are not required for chartered state colleges and universities. (Ibid.)

b. Freedoms included

The institutional academic freedom includes the right of the school or college to decide and adopt its aims and objectives, and to determine how these objections can best be attained, free from outside coercion or interference, save possibly when the overriding public welfare calls for some restraint. (Mercado v. AMA Computer College-Parañaque City, Inc., supra.)

The essential freedoms subsumed in the term “academic freedom” encompass the freedom of the school or college to determine for itself:

1) Who may teach;

2) Who may be taught;

3) How lessons shall be taught; and

4) Who may be admitted to study. (Ibid.)

1) Who may teach

AMACC’s right to academic freedom is particularly important in the present case, because of the new screening guidelines for AMACC faculty put in place for the school year 2000-2001. AMACC has the inherent right to establish high standards of competency and efficiency for its faculty members in order to achieve and maintain academic excellence. The school’s prerogative to provide standards for its teachers and to determine whether or not these standards have been met is in accordance with academic freedom that gives the educational institution the right to choose who should teach. (Ibid.)

It is the prerogative of the school to set high standards of efficiency for its teachers since quality education is a mandate of the Constitution. As long as the standards fixed are reasonable and not arbitrary, courts are not at liberty to set them aside. Schools cannot be required to adopt standards which barely satisfy criteria set for government recognition. (Peña v. NLRC, G.R. No. 100629, 05 July 1996)

The same academic freedom grants the school the autonomy to decide for itself the terms and conditions for hiring its teacher, subject of course to the overarching limitations under the Labor Code. Academic freedom, too, is not the only legal basis for AMACC’s issuance of screening guidelines. The authority to hire is likewise covered and protected by its management prerogative – the right of an employer to regulate all aspects of employment, such as hiring, the freedom to prescribe work assignments, working methods, process to be followed, regulation regarding transfer of employees, supervision of their work, lay-off and discipline, and dismissal and recall of workers. Thus, AMACC has every right to determine for itself that it shall use fixed-term employment contracts as its medium for hiring its teachers. It also acted within the terms of the Manual of Regulations for Private Schools when it recognized the petitioners to be merely on probationary status up to a maximum of nine trimesters. (Mercado v. AMA Computer College-Parañaque City, Inc., supra.)

2) Who may be taught

a) Contract between school and student, imbued with public interest

The contract between the school and the student is not an ordinary contract. It is imbued with public interest, considering the high priority given by the Constitution to education and the grant to the State of supervisory and regulatory powers over all educational institutions. (Non v. Danes II, Mabini Colleges, Inc., supra.)

b) Academic freedom, not a ground for denying students’ rights

The right of an institution of higher learning to set academic standards cannot be utilized to discriminate against students who exercise their constitutional rights to speech and assembly, for otherwise there will be a violation of their right to equal protection. (Non v. Danes II, Mabini Colleges, Inc., supra.)

c) Student does not shed constitutionally protected rights at the schoolgate

Students do not shed their constitutional rights to freedom of speech or expression at the schoolhouse gate. While therefore, the authority of educational institutions over the conduct of students must be recognized, it cannot go so far as to be violative of constitutional safeguards. (Malabanan v. Ramento, G.R. No. 62270, 21 May 1984)

The exercise of the freedom of assembly could not be a basis for barring students from enrolling. It enjoined the school and its officials from acts of surveillance, blacklisting, suspension and refusal to re-enroll. (Non v. Danes II, Mabini Colleges, Inc., En Banc, G.R. No. 89317, 20 May 1990 citing Villar v. Technological Institute of the Philippines, G.R. No. 69198, 17 April 1985)

The academic freedom enjoyed by ‘”institutions of higher learning” includes the right to set academic standards to determine under what circumstances failing grades suffice for the expulsion of students. Once it has done so, however, that standard should be followed meticulously. It cannot be utilized to discriminate against those students who exercise their constitutional rights to peaceable assembly and free speech. If it does so, then there is a legitimate grievance by the students thus prejudiced, their right to the equal protection clause being disregarded. (Villar v. Technological Institute of the Philippines, supra.)

d) Permissible limitations on student exercise of Constitutional Rights within the school

While the highest regard must be afforded the exercise of the rights to free speech and assembly, this should not be taken to mean that school authorities are virtually powerless to discipline students. (Non v. Danes II, Mabini Colleges, Inc., supra.)

But conduct by the student, in class or out of it, which for any reason — whether it stems from time, place, or type of behavior — materially disrupts classwork or involves substantial disorder or invasion of the rights of others is, of course, not immunized by the constitutional guarantee of freedom of speech. (Tinker v. Des Moines Community School District, 393 US 503 [1969] cited in Malabanan v. Ramento, supra.)

3) How lessons shall be taught

The right of the school to discipline its students is at apparent in the third freedom, i.e., “how it shall be taught.” A school certainly cannot function in an atmosphere of anarchy. (Miriam College Foundation, Inc. v. CA, G.R. No. 127930, 15 December 2000)

Thus, there can be no doubt that the establishment of an educational institution requires rules and regulations necessary for the maintenance of an orderly educational program and the creation of an educational environment conducive to learning. Such rules and regulations are equally necessary for the protection of the students, faculty, and property. (Ibid.)

Moreover, the school has an interest in teaching the student discipline, a necessary, if not indispensable, value in any field of learning. By instilling discipline, the school teaches discipline. Accordingly, the right to discipline the student likewise finds basis in the freedom “what to teach.”

a) Right to discipline students

The schools’ power to instill discipline in their students is subsumed in their academic freedom and that “the establishment of rules governing university-student relations, particularly those pertaining to student discipline, may be regarded as vital, not merely to the smooth and efficient operation of the institution, but to its very survival.” (Cudia v. The Superintendent of the Philippine Military Academy [PMA], supra.)

As a Bohemian proverb puts it: “A school without discipline is like a mill without water.” Insofar as the water turns the mill, so does the school’s disciplinary power assure its right to survive and continue operating.The Court has always recognized the right of schools to impose disciplinary sanctions, which includes the power to dismiss or expel, on students who violate disciplinary rules. (Ibid.)

(1) Also a duty to discipline students

Incidentally, the school not only has the right but the duty to develop discipline in its students. The Constitution no less imposes such duty…  All educational institutions shall inculcate patriotism and nationalism, foster love of humanity, respect for human rights, appreciation of the role of national heroes in the historical development of the country, teach the rights and duties of citizenship, strengthen ethical and spiritual values, develop moral character and personal discipline, encourage critical and creative thinking, broaden scientific and technological knowledge, and promote vocational efficiency. (Ibid.)

b) Due process required prior to disciplinary actions

No penalty shall be imposed upon any student, except for cause as defined in this Manual and/or in the school’s rules and regulations duly promulgated and only after due investigation shall have been conducted. (Paragraph 145, Manual of Regulations for Private Schools)

The imposition of disciplinary sanctions requires observance of procedural due process. (Non v. Danes II, Mabini Colleges, Inc., supra.)

There are withal minimum standards which must be met to satisfy the demands of procedural due process; and these are, that

1) The students must be informed in writing of the nature and cause of any accusation against them;

2) They shall have the right to answer the charges against them, with the assistance of counsel, if desired;

3) They shall be informed of the evidence against them;

4) They shall have the right to adduce evidence in their own behalf; and

5) The evidence must be duly considered by the investigating committee or official designated by the school authorities to hear and decide the case. (Guzman v. National University, G.R. No. 68288, 11 July 1986)

(1) Notice and hearing

Notice and hearing is the bulwark of administrative due process, the right to which is among the primary rights that must be respected even in administrative proceedings. The essence of due process is simply an opportunity to be heard, or as applied to administrative proceedings, an opportunity to explain one’s side or an opportunity to seek reconsideration of the action or ruling complained of. So long as the party is given the opportunity to advocate her cause or defend her interest in due course, it cannot be said that there was denial of due process. (Cudia v. The Superintendent of the Philippine Military Academy [PMA], supra.)

(2) Opportunity to be heard

A formal trial-type hearing is not, at all times and in all instances, essential to due process – it is enough that the parties are given a fair and reasonable opportunity to explain their respective sides of the controversy and to present supporting evidence on which a fair decision can be based. “To be heard” does not only mean presentation of testimonial evidence in court – one may also be heard through pleadings and where the opportunity to be heard through pleadings is accorded, there is no denial of due process. (Ibid.)

(3) Counsel

A party in a non-litigation proceeding is entitled to be represented by counsel. The assistance of a lawyer, while desirable, is not indispensable. A party in an administrative inquiry may or may not be assisted by counsel, irrespective of the nature of the charges and of the respondent’s capacity to represent himself, and no duty rests on such body to furnish the person being investigated with counsel. Hence, the administrative body is under no duty to provide the person with counsel because assistance of counsel is not an absolute requirement. (Ibid.)

c) Penalty for violation, proportionate to the offense

The penalty imposed must be proportionate to the offense committed. (Non v. Danes II, Mabini Colleges, Inc., supra.)

If the concept of proportionality between the offense connoted and the sanction imposed is not followed, an element of arbitrariness intrudes. That would give rise to a due process question. (Malabanan v. Ramento, supra.)

4) Who may be admitted

The right to discipline is evident in “who may be admitted to study.” If a school has the freedom to determine whom to admit, logic dictates that it also has the right to determine whom to exclude or expel, as well as upon whom to impose lesser sanctions such as suspension and the withholding of graduation privileges. (Cudia v. The Superintendent of the Philippine Military Academy [PMA], supra.)

a) Discipline extends even after graduation

The power of the school to impose disciplinary measures extends even after graduation for any act done by the student prior thereto. (Ibid.)

In University of the Phils. Board of Regents v. CA, the Court upheld the university’s withdrawal of a doctorate degree already conferred on a student who was found to have committed intellectual dishonesty in her dissertation. (Ibid; See University of the Phils. Board of Regents v. CA, G.R. No. 134625, 31 August 1999)

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”. For it is precisely the “graduation” of such a student that is in question. (University of the Phils. Board of Regents v. CA, supra.)

b) Philipine Military Academy (PMA) has academic freedom

Schools are established not merely to develop the intellect and skills of the studentry, but to inculcate lofty values, ideals and attitudes; nay, the development, or flowering if you will, of the total man. Essentially, education must ultimately be religious, i.e., one which inculcates duty and reverence. Under the rubric of “right to education,” students have a concomitant duty to learn under the rules laid down by the school. Every citizen has a right to select a profession or, course of study, subject to fair, reasonable, and equitable admission and academic requirements. The PMA is not different. As the primary training and educational institution of the AFP, it certainly has the right to invoke academic freedom in the enforcement of its internal rules and regulations, which are the Honor Code and the Honor System in particular. (Cudia v. The Superintendent of the Philippine Military Academy [PMA], supra.)

(1) Honor Code at the PMA

The Honor Code is a set of basic and fundamental ethical and moral principle. It is the minimum standard for cadet behavior and serves as the guiding spirit behind each cadet’s action. It is the cadet’s responsibility to maintain the highest standard of honor. Throughout a cadet’s stay in the PMA, he or she is absolutely bound thereto. It binds as well the members of the Cadet Corps from its alumni or the member of the so-called “Long Gray Line.” (Ibid.)

Likewise, the Honor Code constitutes the foundation for the cadets’ character development. It defines the desirable values they must possess to remain part of the Corps; it develops the atmosphere of trust so essential in a military organization; and it makes them professional military soldiers. As it is for character building, it should not only be kept within the society of cadets. It is best adopted by the Cadet Corps with the end view of applying it outside as an officer of the AFP and as a product of the PMA. (Ibid.)

The Honor Code and System could be justified as the primary means of achieving the cadets’ character development and as ways by which the Academy has chosen to identify those who are deficient in conduct. Upon the Code rests the ethical standards of the Cadet Corps and it is also an institutional goal, ensuring that graduates have strong character, unimpeachable integrity, and moral standards of the highest order. To emphasize, the Academy’s disciplinary system as a whole is characterized as “correctional and educational in nature rather than being legalistic and punitive.” Its purpose is to teach the cadets “to be prepared to accept full responsibility for all that they do or fail to do and to place loyalty to the service above self-interest or loyalty to friends or associates.” Procedural safeguards in a student disciplinary case. (Ibid.)

2. EDUCATION

The State shall protect and promote the right of all citizens to quality education at all levels and shall take appropriate steps to make such education accessible to all. (Section 1, Article XIV, 1987 Constitution)

a. State’s Duties

The State shall:

1) Establish, maintain, and support a complete, adequate, and integrated system of education relevant to the needs of the people and society;

2) Establish and maintain a system of free public education in the elementary and high school levels. Without limiting the natural right of parents to rear their children, elementary education is compulsory for all children of school age;

3) Establish and maintain a system of scholarship grants, student loan programs, subsidies, and other incentives which shall be available to deserving students in both public and private schools, especially to the underprivileged;

4) Encourage non-formal, informal, and indigenous learning systems, as well as self-learning, independent, and out-of-school study programs particularly those that respond to community needs; and

5) Provide adult citizens, the disabled, and out-of-school youth with training in civics, vocational efficiency, and other skills. (Section 2, Article XIV, 1987 Constitution)

1) Highest budgetary priority to education

The State shall assign the highest budgetary priority to education and ensure that teaching will attract and retain its rightful share of the best available talents through adequate remuneration and other means of job satisfaction and fulfillment. (Section 5[5], Article XIV, 1987 Constitution)

b. Educational Institutions

1) Study of the 1987 Constitution

All educational institutions shall include the study of the Constitution as part of the curricula. (Section 3[1], Article XIV, 1987 Constitution)

2) Patriotism and Nationalism

They shall inculcate patriotism and nationalism, foster love of humanity, respect for human rights, appreciation of the role of national heroes in the historical development of the country, teach the rights and duties of citizenship, strengthen ethical and spiritual values, develop moral character and personal discipline, encourage critical and creative thinking, broaden scientific and technological knowledge, and promote vocational efficiency. (Section 3[2], Article XIV, 1987 Constitution)

3) Religion

At the option expressed in writing by the parents or guardians, religion shall be allowed to be taught to their children or wards in public elementary and high schools within the regular class hours by instructors designated or approved by the religious authorities of the religion to which the children or wards belong, without additional cost to the Government. (Section 3[3], Article XIV, 1987 Constitution)

4) Public and private institutions

The State recognizes the complementary roles of public and private institutions in the educational system and shall exercise reasonable supervision and regulation of all educational institutions. (Section 4[1], Article XIV, 1987 Constitution)

5) Ownership

GENERAL RULE: Educational institutions shall be owned solely by citizens of the Philippines or corporations or associations at least sixty per centum (60%) of the capital of which is owned by such citizens. (Section 4[2], Article XIV, 1987 Constitution)

EXCEPTION: … other than those established by religious groups and mission boards. (Ibid.)

a) Schools with foreign students

GENERAL RULE: No educational institution shall be established exclusively for aliens and no group of aliens shall comprise more than one-third (1/3) of the enrollment in any school.

EXCEPTION: The said limitation shall not apply to schools established for foreign diplomatic personnel and their dependents and, unless otherwise provided by law, for other foreign temporary residents. (Paragraph 3, Section 4[2], Article XIV, 1987 Constitution)

b) Power of Congress to increase Filipino equity participation

The Congress may, however, require increased Filipino equity participation in all educational institutions. (Section 4[2], Article XIV, 1987 Constitution)

6) Control and administration

The control and administration of educational institutions shall be vested in citizens of the Philippines. (Paragraph 2, Section 4[2], Article XIV, 1987 Constitution)

7) Tax exemption

a) Non-stock, non-profit educational institutions

All revenues and assets of non-stock, non-profit educational institutions used actually, directly, and exclusively for educational purposes shall be exempt from taxes and duties. (Section 4[3], Article XIV, 1987 Constitution)

Upon the dissolution or cessation of the corporate existence of such institutions, their assets shall be disposed of in the manner provided by law. (Ibid.)

b) Proprietary, for-profit educational institutions

Proprietary educational institutions, including those cooperatively owned, may likewise be entitled to such exemptions subject to the limitations provided by law including restrictions on dividends and provisions for reinvestment. (Paragraph 2, Section 4[3], Article XIV, 1987 Constitution)

c) Grants, endowments, donations, contributions

Subject to conditions prescribed by law, all grants, endowments, donations, or contributions used actually, directly, and exclusively for educational purposes shall be exempt from tax. (Section 4[4], Article XIV, 1987 Constitution)

8) Local planning in development of education policies and programs

The State shall take into account regional and sectoral needs and conditions and shall encourage local planning in the development of educational policies and programs. (Section 5[1], Article XIV, 1987 Constitution)

9) Right to select a profession or course of study

Every citizen has a right to select a profession or course of study, subject to fair, reasonable, and equitable admission and academic requirements. (Section 5[3], Article XIV, 1987 Constitution)

10) Right of teachers to professional advancement

The State shall enhance the right of teachers to professional advancement. (Section 5[4], Article XIV, 1987 Constitution)

Non-teaching academic and non-academic personnel shall enjoy the protection of the State. (Ibid.)

B. Language Added

1. FILIPINO LANGUAGE

a. As national language

The national language of the Philippines is Filipino. As it evolves, it shall be further developed and enriched on the basis of existing Philippine and other languages. (Section 6, Article XIV, 1987 Constitution)

b. Official communication and language of instruction

Subject to provisions of law and as the Congress may deem appropriate, the Government shall take steps to initiate and sustain the use of Filipino as a medium of official communication and as language of instruction in the educational system. (Paragraph 2, Section 6, Article XIV, 1987 Constitution)

2. OFFICIAL LANGUAGES

a. Filipino language and English language

For purposes of communication and instruction, the official languages of the Philippines are Filipino and, until otherwise provided by law, English. (Section 7, Article XIV, 1987 Constitution)

b. Regional languages

The regional languages are the auxiliary official languages in the regions and shall serve as auxiliary media of instruction therein. (Paragraph 2, Section 7, Article XIV, 1987 Constitution)

c. Spanish and Arabic languages

Spanish and Arabic shall be promoted on a voluntary and optional basis. (Paragraph 3, Section 7, Article XIV, 1987 Constitution)

3. 1987 CONSTITUTION

The 1987 Constitution shall be promulgated in Filipino and English and shall be translated into major regional languages, Arabic, and Spanish. (Section 8, Article XIV, 1987 Constitution)

4. NATIONAL LANGUAGE COMMISSION

The Congress shall establish a national language commission composed of representatives of various regions and disciplines which shall undertake, coordinate, and promote researches for the development, propagation, and preservation of Filipino and other languages. (Section 9, Article XIV, 1987 Constitution)

C. Science and Technology Added

1. NATIONAL DEVELOPMENT AND PROGRESS

Science and technology are essential for national development and progress. (Section 10, Article XIV, 1987 Constitution)

1) To be given priority

The State shall give priority to research and development, invention, innovation, and their utilization; and to science and technology education, training, and services. It shall support indigenous, appropriate, and self-reliant scientific and technological capabilities, and their application to the country’s productive systems and national life. (Ibid.)

2) To be given incentives

a) Tax deductions, etc.

The Congress may provide for incentives, including tax deductions, to encourage private participation in programs of basic and applied scientific research. (Section 11, Article XIV, Ibid.)

b) Scholarships, grants-in-aid, etc.

Scholarships, grants-in-aid, or other forms of incentives shall be provided to deserving science students, researchers, scientists, inventors, technologists, and specially gifted citizens. (Ibid.)

2. REGULATION ON TRANSER AND PROMOTION

The State shall regulate the transfer and promote the adaptation of technology from all sources for the national benefit. It shall encourage the widest participation of private groups, local governments, and community-based organizations in the generation and utilization of science and technology. (Section 12, Article XIV, Ibid.)

1) Protection and secure exclusive rights

The State shall protect and secure the exclusive rights of scientists, inventors, artists, and other gifted citizens to their intellectual property and creations, particularly when beneficial to the people, for such period as may be provided by law. (Section 13, Article XIV, 1987 Constitution)

D. Arts and Culture Added

1. FILIPINO NATIONAL CULTURE

a. Principle of unity and diversity

The State shall foster the preservation, enrichment, and dynamic evolution of a Filipino national culture based on the principle of unity in diversity in a climate of free artistic and intellectual expression. (Section 14, Article XIV, 1987 Constitution)

2. ARTS AND LETTERS

a. Historical and cultural heritage and resources; Artistic creations

Arts and letters shall enjoy the patronage of the State. The State shall conserve, promote, and popularize the nation’s historical and cultural heritage and resources, as well as artistic creations. (Section 15, Article XIV, 1987 Constitution)

1) Cutural treasure of the nation

All the country’s artistic and historic wealth constitutes the cultural treasure of the nation and shall be under the protection of the State which may regulate its disposition. (Section 16, Article XIV, 1987 Constitution)

3. INDIGENOUS CULTURAL COMMUNITIES

The State shall recognize, respect, and protect the rights of indigenous cultural communities to preserve and develop their cultures, traditions, and institutions. It shall consider these rights in the formulation of national plans and policies. (Section 17, Article XIV, 1987 Constitution)

4. EQUAL ACCESS TO CULUTURAL OPPORTUNITIES

The State shall ensure equal access to cultural opportunities through the educational system, public or private cultural entities, scholarships, grants and other incentives, and community cultural centers, and other public venues. (Section 18[1], Article XIV, 1987 Constitution)

5. RESEARCH AND STUDIES ON THE ARTS AND CULTURE

The State shall encourage and support researches and studies on the arts and culture. (Section 18[2], Article XIV, 1987 Constitution)

E. Sports Added

1. DEVELOPMENT OF A HEALTHY AND ALERT CITIZENRY

The State shall promote physical education and encourage sports programs, league competitions, and amateur sports, including training for international competitions, to foster self-discipline, teamwork, and excellence for the development of a healthy and alert citizenry. (Section 19[1], Article XIV, 1987 Constitution)

1) Regular sports activities

All educational institutions shall undertake regular sports activities throughout the country in cooperation with athletic clubs and other sectors. (Section 19[2], Article XIV, 1987 Constitution)

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