[Higher Education Leadership Forum Philippines (Manila, 28-29 June 2016)]
I would like to thank the organizers of this forum for inviting me to share my personal reflections on critical issues which affect Higher or Tertiary Education in the Philippines. I would like to do so in the framework the Roadmap for Philippine Tertiary Education of the Coordinating Council of Philippine Educational Associations (COCOPEA), the umbrella organization of five different private educational associations, uniting some 2,500 colleges, universities and technical-vocational institutions or Higher Educational Institutions (HEIs) in the Philippines. This Roadmap was unanimously approved just last May 19, 2016 by the COCOPEA Board of Trustees. I was part of the committee which worked on it, complementing an earlier version of the Roadmap articulated by Dr. Don Brodeth. Presenting the approved COCOPEA Roadmap manifests my personal thoughts, but also the collective thought of COCOPEA.
Higher Education Drift
While the administration of Pres. Benigno Aquino III, who campaigned as an education president (2010-2016), was a period of great energy, renewal, achievement and excitement for basic education due to the substantially successful K-12 reform, it was a period of drift for higher education. Part of this was because the magnitude of the K-12 reform required the nation and its educators to focus on its demands: deciding on how the international deficit of two years would be remedied, establishing through law a two-year senior high school (SHS, Grades 11-12) after high school (Grades 1-10, now Junior High School), determining how to decongest and improve the old curriculum, how to insure greater survival of student cohorts, how to integrate erstwhile tertiary level courses ejected into SHS, how to make senior high school a general preparation for college while accepting that many students could opt to work immediately after graduation, how to establish SHSs appropriate to the cultures of our indigenous peoples, how to provide enough teachers and classrooms for SHS through partnership with the private sector, how to fund SHS, and how to manage the effects of SHS on the tertiary operation.
The general focus of educational policymakers and administrators was on SHS, or on the effect its introduction would have on HEIs, especially on stand-alone HEIs. It was not on tertiary education. Meanwhile CHED’s vision of being “a key leader and effective partner in transforming HEIs towards producing highly competent and productive professionals through dynamic, excellent, and client-oriented services” remained a mere vision, with competent and productive professionals being produced in the absence of or despite CHED’s “leadership and partnership;” they were also produced in the relative absence of “dynamic, excellent and client-oriented services”. In pursuit of its mission: “…to provide effective central policy direction and implement programs and mechanisms to ensure affordable quality higher education accessible to all” CHED’s apparent central policy direction, CM0 46 s. 2012, was confused, onerous, paralyzing and divisive. Part of this was its major attempt to link quality assurance with HEI typology and outcomes-based education, while there was no general consensus on what “quality” is, and therefore no consensus on the crucial importance in quality assurance of minimum standards, academic excellence, the implementation of the HEIs vision and mission, and the responsiveness of the HEI to its stakeholders.
In the discussions, outcomes-based education, outcomes-based quality assurance, learner outcomes and competencies were confused. For CHED, the major stakeholder of Philippine higher education was – apodictically – industry and the jobs market aligned with the economic goals of the Aquino administration, while many HEIs considered their major stakeholder not industry but society as a whole with its complex problems of moral degeneration, unbridled consumerism, economies that exclude and marginalize people, corruption, environmental destruction, religious extremism, and loss of cultural identities in a globalized world. CMO 46’s typologies were contentious in their requirements and the attempt at “outcomes-based quality assurance” – different from outcomes-based education – was an attempt at absurdity. For how assure the quality of outcomes if assurance is based on outcomes? Meanwhile, relative weights for program accreditation vs. Institutional Sustainability Assessment were contentious.
Officials’ admissions that at least the language of CMO 46 had to be altered to protect the guaranteed academic freedom of HEIs were ignored in actual policy, allowing the confusion and frustration to fester. Thus, the determination of autonomous and de-regulated schools based on CMO 46 was postponed and re-postponed in the confusion. The announcement of the new or renewed autonomous and de-regulated HEIs, which should have been made in 2014, was published only last month, but now with no clarification from CHED as to why the autonomous or deregulated status for a few schools was effective for five years, but for the majority for three years, and for others for one year. The effect on many schools was demoralization. Over the years, the schools had spent valuable time, expense and energy trying to understand and comply with vague policies and non-transparent criteria; the outcome was a list of autonomous and deregulated schools whose criteria of selection and duration of validity were opaque, if not arbitrary.
Meanwhile CHED’s mission to “implement programs and mechanisms to ensure affordable quality higher education accessible to all” relied on enhancing public provision of education through an increase in SUCs and scholarship assistance focused on state-funded SUCs, rather than on private HEIs. This left huge sums of scholarship money unused, that is, large numbers of potential scholars unsupported. The policy option to favor public schools in scholarship distribution exacerbated the unlevel playing field between public and private schools, where CHED’s “reasonable regulation” can close private schools which the State does not fund, but not public schools created by law which the State funds. Under the 1987 Constitution which considers the role of the private sector “indispensible” for development and recognizes the complementary roles between public and private schools within a system of education the State is mandated to provide, what little “leadership” CHED provided in supporting private HEIs and public private partnerships was either largely ineffective or legally dubious.
What contributed to the tertiary education drift was CHED’s lack of leadership in bringing about a clear consensus among academically free HEIs as to development of tertiary education in the Philippines. Where would higher education go? Conferences on policy directions involving public and private universities were convened by the private sector with a focus on industry needs, not by CHED with a focus on broader national needs. Today, Philippine Tertiary Education is marching in mark time: marching, but not clearly going anywhere. Meanwhile, in exercise of academic freedom, the community of HEIs, public and private, did not determine clear targets of how it could function in the service of truth, including not only the economy, but also such as the environment, the development of renewable energy, the effect of media on morality, and the historical injustice done over the centuries to Muslim Filipinos in Mindanao? Could it not have worked to achieve and deepen a shared understanding of academic freedom complemented by quality assurance? Could it not have worked to address the complementary roles of public and private schools in a State-provided system of education that must be accessible to all? Could it not have addressed the challenge of quality assurance according to ASEAN or international standards, and not have been confined to CMO 46? Could it not have reflected on how best to use available public funds for the development of a higher education system that necessarily includes the private sector? While the CHED is a body of academic peers designed to engage academically free HEIs in consensus building, its Chair shied away from direct dialogue and consensus building with HEI leaders and preferred to govern by fiat. Among so many educated educational leaders, CHED positions were necessarily contentious. They were introduced in a CHED culture of consultations that do not encourage study, thought and reflection, where criticism is unwelcome, and problems unresolved. The other commissioners, higher education peers, who could have catalyzed the dialogue among the educators, behaved like undersecretaries and obeyed the Chair. Meanwhile, the higher education community continued to operate largely tangential to the CHED bureaucracy, avoiding engagement lest actual HEI operations be disturbed. The less CHED interference, the better.
Ironically, because the CHED governed fundamentally by fiat, as in the determination of program content through the policies, standards and guidelines determined by the central Technical Working Groups, academically free HEIs throughout the country became increasingly, if not fully, dependent on the determinations of the Technical Working Committees, binding as “minimum standards” on all, despite the fact that in some cases these were not minimum but optimum standards determined by the educators of certain select HEIs mostly in the NCR. The increasing dependence progressively killed the academic freedom and eros to search for new truth, for better ways to discover truth, for more effective ways to teach truth in local situations, for improved ways of serving the community through truth. All the higher education institutions had to do was to wait for the program requirements promulgated by CHED based on the deliberation of the related TWG; initiative to innovate old programs and create new was killed. While the 1987 Constitution mandated “the enjoyment of academic freedom in all institutions of higher learning” and RA 7722 mandated CHED to “ensure and protect academic freedom” and “promote its exercise and observance for the continuing intellectual growth, the advancement of learning and research, the development of responsible and effective leadership, the education of high-level and middle-level professionals, and the enrichment of our historical and cultural heritage” the whole relationship between CHED and the HEIs was not promoting but killing the exercise of academic freedom in the HEIs. It was not the HEIs exercising academic freedom, but the CHED; not the 2500 HEIs of the country, a rich resource for innovation and new learning, but the five Commissioners, or in some cases, the CHED Chair. Willy nilly, CHED usurped academic freedom from the HEIs.
Where the Roadmap leads.
It is from the midst of this situation that the COCOPEA Roadmap emerges, a roadmap based on the Vision and Mission of COCOPEA. In its Vision statement, COCOPEA assumes “the strong and leading role of private education” in the Philippines “as vital to human development.” In its Mission statement, COCOPEA declares that it “advances, promotes and protects (1) Academic freedom; (2) Quality education; (3) the essential complementarity between public and private education; (4) the healthy governance of private higher educational institutions based on autonomous self-governance and reasonable government regulation; (5) personal development, social justice and the common good.
Against the higher educational drift, the marching in mark time, COCOPEA envisions a clear objective or goal based on principles of the 1987 Constitution and on its own vision and mission:
COCOPEA’s ultimate goal is a “complete, adequate and integrated system of quality higher education” for ALL in the Philippines. This is composed of public and private HEIs working in necessary and achieved complementarity in the pursuit and in the communication of truth in academic freedom through:
- instruction and formation of the human person;
- research and innovation; and
- service to the community.
COCOPEA believes that part of the complementarity between public and private education is the articulation of the constitutional recognition “of the indispensible role the private sector plays in development” and nowhere is this more evident than in education.
COCOPEA also sees this higher education system to be governed autonomously (free from ephemeral [party] political interference, the control of stakeholder interests, the control of the economic elite) and supported appropriately by public funds and reasonable government regulation.
In this goal, one may appreciate six integrated parts: (1) the mandated system of education the State must provide for all; (2) within this system, the complementarity between public and private education; (3) academic freedom in pursuit of truth through instruction, research and service to the community complemented by quality assurance; (4) autonomous self-governance by the HEIs vested with academic freedom, not CHED; (5) the use of public funds to support this system, and finally (6) reasonable government regulation. It is to pursue this goal that COCOPEA articulates its Roadmap.
The Roadmap treats four major aspects of this goal. Each aspect is discussed. Each discussion leads to concrete action resolutions. In this presentation I will only choose points which I consider urgent agenda vs. current realities.
Advancing, promoting and protecting academic freedom and quality education
COCOPEA stresses the constitutional guarantee of academic freedom enjoyed by all HEIs and the mandate of CHED to ensure and protect academic freedom and to promote its exercise and observance. This was discussed above.
The academic freedom of the HEIs – “institutional academic freedom” – includes “the right of an HEI to decide and adopt its objectives and determine how these objectives can best be obtained, free from outside coercion and interference” That includes government coercion and interference.
It is in harmony with the jurisprudential understanding of academic freedom as the right of the institution to determine who may teach, whom may be taught, what is taught, how it is taught.
More fundamentally, in its Roadmap goal, COCOPEA links academic freedom to the pursuit and communication of truth through instruction, research and service to the community.
It aligns itself therefore with the traditional finality of the university as the pursuit of truth in academic freedom, and therefore rejects the external subjugation of the university, the HEI, or the community of HEIs to the needs and objectives of a religious aggrupation like the Catholic Church or Islam, a political entity such as the nation, or a national or global concern like the interdependent economies of the nation or globe.
It recognizes that HEIs must proactively exercise this academic freedom, using its own community of professors, teachers, researchers and scholars to teach, discover and serve truth in stakeholder communities, and not be dependent on CHED to determine this for them. Beyond the notions a particular political administration may have of the needs of the economy, the HEIs are free to criticize the nature of those needs or the validity of the economic model in the interests of truth. The HEIs are free to reject obeisance to a notion of a “quality nation” externally and arbitrarily imposed.
Beyond the economy and the nation, the HEIs are free to pursue the truth of God, nature and the human being in human society. They are free to investigate the truth of religious freedom or coercion, environmental degradation, excessive and wasteful consumerism, social exclusion, moral degeneration, violence arising from religious exclusiveness and extremism. They are free to investigate social diversity and the planet based on the social and natural sciences, the first principles in the contemplation of being, and the meaning of revelation for our world today, if indeed revelation is an object and condition of faith. They are free to articulate the historical injustice done to the Bangsamoro and indigenous peoples in Philippine history and to warn society of the consequences in climate change of failure to reduce carbon emissions. They are free to bring these investigations to bear on current society.
Academic freedom distinguishes higher education from basic education, and its institutional exercise is essential for quality higher education. Here, quality refers to the ability of the HEI to achieve minimum standards set by government, to distinguish itself in surpassing minimum standards to achieve academic excellence through learning, research and service outcomes, to implement its mission and vision declared in academic freedom, and to respond to its stakeholders.
Because academic freedom is linked to truth and quality education, in the interest of truth and quality, it implies quality assurance. In academic freedom, HEIs engage freely in quality assurance. Quality assurance on the level of both academic programs and institutions is their responsibility in academic freedom. COCOPEA states: “Academic freedom without quality assurance is reckless; however, quality assurance without academic freedom is empty.” Imposed quality assurance that kills academic freedom kills higher education. Externally imposed quality assurance that subjects HEIs to goals they do not freely embrace kills academic freedom.
In pursuit of academic freedom, COCOPEA commits itself, among others to: (1) Undertake, in consultation with other concerned sectors, a review of paralyzing governmental regulation or programs that violate institutional academic freedom and ensure that regulation sticks to minimum standards pursuant to the legal mandate granted to the CHED under RA 7722. (2) Take the lead in a national dialogue involving higher education leaders, academicians, education stakeholders, et al, towards achieving a collective understanding of “quality” in higher education.
Advancing, promoting and protecting the essential complementarity between public and private education.
The role of private education in the Philippines cannot be taken lightly. The Royal and Pontifical University of Santo Tomas (UST) of the Dominicans was established in 1611. The Ateneo de Manila and the Colegio de San Jose of the Jesuits were established in 1859 and 1601 respectively. The Protestant Silliman University was established in 1901. All were operating and producing higher education graduates long before the State-run University of the Philippines was established in 1908.
CHED was established by law only in 1994.
Among the finest and most innovative of the nation’s HEIs are private. Many of these are operating in remote areas.
Today there are 1708 private HEIs operating in the PH as opposed to 227 public HEIs.
However, despite the greater number of private HEIs, the share of the public HEIs in higher education enrollment has been increasing.
Using available comparative figures between SY 2008-09 and SY 2014-15, the total enrollment increased from 2,627,799 to 3,911,796. The total enrollment in public HEIs increased from 984,245 to 1,684,088 or by 71%. For public schools therefore there was a marked increase in its share of the total enrollment from 37.5% to 44.2%. On the other hand, while the total enrollment in the private HEIs increased from 1,643,503 to 2,127,693, the percentage share for private HEIs decreased from 62.5% to 55.8%.
With the increasing clamor for access to higher education, Congress seems inclined to yield to the pressure of voters for more SUCs, despite CHEDs discouragement of new HEIs for reasons of quality. Public funding and scholarship money has poured into SUCs to increase access, even as SUCs are now charging tuition, providing crippling state-funded competition to some private HEIs.
Funding for SUCs increased from P19,338,337,000 in 2008 to P35,934,625,000 in 2014 to P47,414,727,000 in 2016, an increase of 185% between 2008 and 2014 (for an increase in student population of only 71%), or of 245% between 2008 and today. Should the share of the public schools in the enrollment keep increasing, even forcing some private HEIs out of business, would government be able to afford it? Will the overall quality of the educational system increase or decrease with decreasing private sector share in the total enrollment? While some SUCs are excellent, a major problem of SUCs is their vulnerability to the meddling of party politicians and their lack of effective supervision from CHED due to their charters. While some private HEIs are excellent, their excellence seems to depend on charging high fees.
In this context, the COCOPEA Roadmap position is: “COCOPEA believes that the Philippine Government, in its responsibility to ‘protect and promote the right of all citizens to quality education at all levels’ must view the private HEIs as indispensable partners to ensure that quality higher education is made ‘accessible to all’. The Constitution recognizes the ‘complementary roles of public and private institutions in the educational system…” even as the State ‘shall exercise reasonable supervision and regulation of all educational institutions.’ Moreover, the State “affirms the ‘indispensable role of the private sector, encourages private enterprise, and provides incentives to needed investments.’”
On the basis of this indispensible partnership and complementarity, COCOPEA, among others, undertakes to advocate “that in all educational legislation the principle of ‘leveling the playing field’ for all public and private HEIs be heeded. Moreover the government regulatory framework on HEIs must exhibit this “level playing field.” Among many measures advocated in this context: “an increase of Public-Private Partnerships in favor of private HEIs, Educational Service Contracting for tertiary education, equality of compensation between public and private school teachers for similar disciplines, equity in distribution of state-funded scholarships between private and public schools., etc.”
Advancing the healthy governance of higher educational institutions based on autonomous self-governance and supported by public funds and reasonable regulation.
Since the 1987 Constitution mandates the enjoyment of academic freedom in HEIs, and the law mandates CHED to “ensure and protect academic freedom and to promote and exercise its observance” stating that “nothing in this Act shall be construed as limiting the academic freedom on universities and colleges”, HEIs cannot be governed by orders as the basic education schools are governed by the Secretary of Education, but must be self governing in the implicit autonomy of academic freedom limited only by its finality in truth and quality education, as discussed above.
The Roadmap states:
“COCOPEA believes that higher education (the complete, adequate and integrated system of higher education) governs itself. CHED as a collegial body [not only of commissioners but of higher education academic peers], supports and calls forth this self-governance per RA 7722 and promotes the complementarity between public and private education.
“CHED, as the government agency created pursuant to RA 7722, must understand that it is not “above” the higher education community. All universities, whether public (organized directly by the State) or private (organized by the private sector in contribution to the work of the State) are created by law and subject to the governance of the higher education community which the CHED serves. As such, CHED shall confine itself in academic regulation to minimum standards for programs and institutions after consultations with the higher education community. It shall set these minimum standards and enforce them, whenever possible.
“However CHED can and should encourage awards and celebrate programs for outstanding academic instruction, research and service to the community. It can also shut down programs or institutions that do not achieve or follow minimum standards. Beyond minimum standards, all HEIs should be free to govern themselves – in academic freedom and quality assurance.”
“This understanding of ‘healthy governance’ fosters dialogue and consensus building on shared governance. ‘Healthy governance’ also connotes distribution of state funds for HEIs, whether public or private, accordance to evidenced quality or accessibility demands.”
In this context COCOPEA advocates, among others, “(1) the fulfillment by CHED of its mandates as articulated in RA 7722 [Sec.8], (2) the study of the Government regulatory framework relative to the over-regulation of private higher education; (3) the self governance in academic freedom and quality assurance by all HEIs”. A consensus on how must be achieved.
COCOPEA would represent the private sector.
Advancing, promoting and protecting advocacies on personal development, social justice, and the common good.
The final aspect of Roadmap goal is determined by the COCOPEA mission and pertains to shared content accepted in academic freedom: matters which pertain to the development of the person, to social justice and the common good.
The development of the person includes issues of human freedom, moral formation, the human individual, and human culture and society. Beyond commutative and distributive justice, COCOPEA focus on social justice. Social justice leads to the common good – that state where each person and every person thrives optimally as human beings within a given set of historical conditions. Because of the depth or contentiousness of these foci, the are most fruitfully treated within the multi-disciplinarity of higher education institutions. Among the concrete topics listed in the Roadmap are:
- Love for Philippine identity and national heritage.
- Wealth creation and its equitable distribution.
- Environmental conservation and protection.
- Personal development (self-awareness, service to society, cultural sensitivity, leadership)
- The common good
- Conflict resolution (i.e., economic development vs. environment; public good vs. private good; human rights vs peace and order)
- Religious inclusiveness and tolerance
Ladies and Gentlemen, if in this conference we are looking for where educational leadership pertinent to higher education in the Philippines is necessary, the COCOPEA Roadmap for Higher Education provides ample challenge for leadership. First, that the HEIs themselves, whether private or public, lead in academic freedom in setting the directions for Philippine higher education, and in this context determine what to teach, whom to teach, who may teach and how to teach. Second, that government truly promote and protect the enjoyment of academic freedom in each HEI and in all HEIs, focusing its activities on setting minimum standards for programs and institutions, and enforcing these. Third, that the private sector lead in achieving consensus on the demands of quality and quality assurance in Philippines. Fourth, that that the private sector and government lead in achieving genuine complementarity between public and private HEIs. Fifth, that the HEI community govern itself in the academic freedom granted HEIs by the Constitution. The HEIs must lead in establishing the structures of their self-governance, and that legislators lead in dismantling the ill-used, if not illegal customary powers of CHED through which it usurps the academic freedom of the HEIs. In this manner let the HEIs lead in providing the country critically needed resources in reliable and innovative instruction, research and service to the Philippine and human community.
 COCOPEA’s member associations with number of members: Association of Christian Schools, Colleges and Universities (ACSCU, 210), Catholic Educational Association of the Philippines (CEAP, 2340), Philippine Association of Colleges and Universities (PACU, 160), Philippine Association of Private Schools, Colleges and Universities (PAPSCU, 120), Technical-Vocational School Association of the Philippines (TEVSAPHIL, 400)
 Submitted to the COCOPEA Board as commissioned by the same by Dr. Don Brodeth on Nov. 25, 2015.
 CMO 20 s. 2016
 In the last COCOPEA Board Meeting of May 19, 2016 it was reported that when the Commission saw the original list of only a few Autonomous and De-Regulated schools, it ordered the list increased.
 Despite CHED’s efforts to discourage new SUCs, their number increased from 205 in 2008-09 to 227 in 2014-15. In the same period the percentage of total enrollment in public schools increased from 37.5% to 44.2%, while the percentage of total enrollment in private schools decreased from 62.5% to 55.8%.
 The Commission on Audit (COA) report on CHED’s 2014 performance showed “internal control weaknesses in the administration of the CHED’s Student Funding Assistance Program (STUFAP). These affect the allocation of beneficiary slots, and the processing of claims and their release. Findings: (a) Allotments of 1.23 billion are unutilized. These delay the availment by students of the program in the CHED regional offices (CHEDROs). (b) The total slot allocation of 391,837 students is beyond the absorptive capacity of the CHEDROs to which they were downloaded. (c) For 703 grantees, there are excess, double or multiple payments of benefits totaling PHP 3,441,500. This reeks not only of inefficiency but of fraud. (d) The payment of benefits through cash advances by the cashier and other officials had a total unliquidated year-end balance of PHP 108,001,505 in CHEDROs I, V, and VI. Here there are no assurances that the grantees received their educational assistance.
 Whereas DepEd entered into public-private partnerships (PPPs) with private schools through Educational Service Contracting and the Voucher Program for public school gradates opting to study in SHSs, there is no such broad program for government and private tertiary education. Meanwhile, the COA report for 2014 on the Philippine California Advanced Research Institutes (PCARI) project shows only 0.28 percent of its 2.846 billion were used due to policy differences between CHED and the DOST.
 Cf. COA report for 2014, paragraphs 178, 182-184, 189-191
 Par. 2, Sec. 5, Article XIV
 Sec. 2, RA7722. cf. also Sec. 13 “Guarantee of Academic Freedom”: “Nothing in this Act shall be construed as limiting the academic freedom of universities and colleges….”
 Adapted from par. 1. sec 2, art. XIV of the 1987 Constitution
 cf. par. 1. sec 1, art. XIV of the 1987 Constitution
 cf. par. 1. sec 4, art. XIV of the 1987 Constitution
 cf. sec 2, art. XIV of the 1987 Constitution
 cf. par 2, sec. 5, art. XIV of the 1987 Constitution, and Supreme Court of the Philippines, GR 183572)
 Cf. Enrique M. Fernando, “Academic Freedom as a Constitutional Right” written in the Philippine Law Journal, Vol. 52, No. 3-03: “Justice Frankfurter, with his extensive background in legal education as a former Professor of the Harvard Law School, referred to what he called the business of a university and thr four essential freedoms in the following language. ‘It is the business of a university to provide that atmosphere which is most conducive to speculation, experiment and creation. It is an atmosphere in which there prevail ‘the four essential freedoms’ of a university: – to determine for itself on academic grounds who may teach, what may be taught, how it shall be taught, and who may be admitted to study” (underscoring mine).
 Contentious, therefore, in CMO 46 s. 2013 is the apodictic determination by CHED that HEIs in the Philippines must “contribute to the building of a the quality nation…” (Art. 1. Sec 1) without even defining what a quality nation is. In a quality assurance document issued by CHED for all HEIs, public and private, the CHED determination was a cooptation of the right of HEIs to determine its relationship to the nation and to other aspects of truth, and so was a violation of academic freedom guaranteed to HEIs. Academic freedom is vested in the HEIs, not in CHED.
 Sec. 1, Art. XIV, 1987 Philippine Constitution
 par. 1, Sec. 4, Art. XIV, 1987 Philippine Constitution
 Sec. 20, Art. 2., 1987 Philippine Constitution
 Sec. 13, RA 7722. Cf. also Sec. 2.
 Among the few clear powers of CHED: “set minimum standards for programs and institutions of higher learning recommended by panels of experts…” RA 7722, Sec. 8 (d).