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June

28, 2014

To Mr. Rey Reyes, (cc Dean Ricardo Lim)





DYSFUNCTIONAL BEHAVIOR COMPLAINT




DOCTOR HAZEL PARAGUA

1. Complainant, Khristine Carissa Consuelo Malig Consunji, is charging MDM
2014 Program Director Doctor Hazel Paragua with repeated bullying and
harassment, coupled with discriminatory behaviors towards Complainant
and lack of impartial behavior as well as favoritism towards a dysfunctional
academic behavior complaint brought to her by Complainant about Class
Officer Armando Lee. Thus, Doctor Paragua is also being charged with
academic dysfunctional behavior for condoning plagiarism on the part of
Class Officer Armando Lee.


2. In the following e-mail exchange with Armando Lee, Complainant noted that
she was uncomfortable with Class Officers asking for Stakeholder Analysis
Powerpoints for the Marketing Class by Professor Gavino:

---------- Forwarded message ---------From: Armando Lee <aclee.mdm2014@myapps.aim.edu>
Date: Wed, Feb 26, 2014 at 10:34 AM
Subject: Re: Learning Team 6 Stakeholder Analysis - Bureau of Customs
To: Khristin Consunji <kconsunji.mdm2014@myapps.aim.edu>
Dear Chin,
OK. No problem. Im not forcing the issue.
-Arman
On Wed, Feb 26, 2014 at 9:21 AM, Khristin
Consunji <kconsunji.mdm2014@myapps.aim.edu> wrote:
Hi Arman,
I already referred this matter to Dean Luz and Doctor Hazel. As we stated, we
are more comfortable submitting directly to Dr. Gavino, for our own reasons.
Please do not force the issue.
Chin

On Tue, Feb 25, 2014 at 11:03 PM, Armando


Lee <aclee.mdm2014@myapps.aim.edu> wrote:
Chin,
Can you please send me a copy of your ppt too? I need to include it to the class
ppts.
Thanks.
-Arman
On Tue, Feb 25, 2014 at 10:58 PM, Khristin
Consunji <kconsunji.mdm2014@myapps.aim.edu> wrote:
Hi Arman,
We will just submit our work directly to Professor Gavino.
Thank you,
Chin
On Mon, Feb 24, 2014 at 8:43 AM, Armando
Lee <aclee.mdm2014@myapps.aim.edu> wrote:
Chin,
Please understand im only doing this because of deadlines set by our Prof. If i
were not given the task i would not have done setting deadlines too. Next time, i
will ask our Prof to assign somebody else (not officer) so the issue will not be set
on the officers in the class. Cheers.
-Arman
On Sun, Feb 23, 2014 at 11:33 PM, Khristin
Consunji <kconsunji.mdm2014@myapps.aim.edu> wrote:
Hi Arman,
I think this deadline is a little too close, given all the other work we need to do. I
understand you were assigned the responsibility of choosing the presentations
but you also have to be considerate of our schedules and timing constraints-while I respect your position as class president, I would reconsider your approach
to assigning academic work and imposing deadlines on us on very short notice-I believe that is something only instructors can do and not class officials.
Best,
Chin

On Sun, Feb 23, 2014 at 5:47 PM, Armando


Lee <aclee.mdm2014@myapps.aim.edu> wrote:
Please make the 4 slides ppt right away and email me a copy (due tomorrow
AM). Make a hard copy too and submit it to Prof Gavino next class session with
him.
-Arman
On Fri, Feb 21, 2014 at 3:07 PM, Armando
Lee <aclee.mdm2014@myapps.aim.edu> wrote:
Or is the Bureau of Customs your identified stakeholder already?

On Fri, Feb 21, 2014 at 3:06 PM, Armando


Lee <aclee.mdm2014@myapps.aim.edu> wrote:
OK. Who is your major stakeholder in BC?

On Fri, Feb 21, 2014 at 2:32 PM, Khristin


Consunji <kconsunji.mdm2014@myapps.aim.edu> wrote:
Hi Arman,
We're doing a stakeholder analysis of the Bureau of Customs.
Best,
Chin


3. Complainant was hesitant to submit academic work to a fellow student or the
autocratic approach taken by Class Officer Armando Lee taken towards
submission of work by classmates. She was also uncomfortable with the
approach taken by class officer Armando Lee towards the issue as she did not
believe it was within the mandate of Class Officers to ask for and assign
academic work.

4. On February 24, 2014, Complainant had following text message exchange


with teammate Rommel Rubiales:
February 24, 2014 4:59 pm Rommel 09209507432:
Chin the group is productive with you as our Leader, I think Father is the
only one not contributing. We can ask him if he wants to transfer to another
group.

February 24, 2014 5:00 pm Complainant 09212549616:
Ok, but I think we should bring that up soon. I will email the spreadsheet of
work accomplished, I can ask Dean Luz. You called earlier?
February 24, 2014 5:01 pm Rommel 09209507432:
Yes, sorry to disturb you but I just want to tell you something I found just last
week.
February 24, 2014 5:02 pm Complainant 09212549616:
Ah will call now.
February 24, 2014 5:04 pm Rommel 09209507432:
Chin I am with our classmates now we are drinking. Its regarding our
concept notes.
February 24, 2014 5:04 pm Complainant 09212549616:
Ah ok! I am in greenbelt now.
February 24, 2014 5:05 pm Complainant 09212549616:
Why, what about the notes?
February 24, 2014 5:08 pm Rommel 09209507432:
Chin this will just be between the two of us, Dr. Arman copied word for word
parts of my submitted concept notes (presentation) within the Google Drive
of Prof Ron Chua.
February 24, 2014 5:08 pm Complainant 09212549616:
P****** ina niya!
February 24, 2014 5:09 pm Complainant 09212549616:
Oh my god.
Sorry Mel but that is terrible!!!

February 24, 2014 5:10 pm Complainant 09212549616:
Did you want to discuss it with someone on the faculty?
February 24, 2014 5:13 pm Rommel 09209507432:

Chin, I will not do that. You can check our Google Drive and you can compare
our work. That constitutes violation of Academic Honesty but I am not
reporting it because I respect our class.
February 24, 2014 5:17 pm Complainant 09212549616:
Ok, my god that is terrible. I will do it now.

5. Part of the initial exchange between Complainant and Armando Lee was
copy-furnished to the MDM 2014 thread:




---------- Forwarded message ---------From: Khristin Consunji <kconsunji.mdm2014@myapps.aim.edu>
Date: Tue, Feb 25, 2014 at 10:58 PM
Subject: Re: Learning Team 6 Stakeholder Analysis - Bureau of Customs
To: Armando Lee <aclee.mdm2014@myapps.aim.edu>
Cc: Ismeera Qadeer <iqadeer.mdm2014@myapps.aim.edu>, Rommel Rubiales
<rrubiales.mdm2014@myapps.aim.edu>, Ripon Rozario
<rrozario.mdm2014@myapps.aim.edu>, Leka Pitoi
<lpitoi.mdm2014@myapps.aim.edu>, Dong Nguyen Thi Thu
<nguyenthithudong@gmail.com>, MDM 2014 <MDM2014@myapps.aim.edu>
Hi Arman,
We will just submit our work directly to Professor Gavino.
Thank you,
Chin
On Mon, Feb 24, 2014 at 8:43 AM, Armando
Lee <aclee.mdm2014@myapps.aim.edu> wrote:
Chin,
Please understand im only doing this because of deadlines set by our Prof. If i
were not given the task i would not have done setting deadlines too. Next time, i
will ask our Prof to assign somebody else (not officer) so the issue will not be set
on the officers in the class. Cheers.
-Arman

On Sun, Feb 23, 2014 at 11:33 PM, Khristin


Consunji <kconsunji.mdm2014@myapps.aim.edu> wrote:
Hi Arman,
I think this deadline is a little too close, given all the other work we need to do. I
understand you were assigned the responsibility of choosing the presentations
but you also have to be considerate of our schedules and timing constraints-while I respect your position as class president, I would reconsider your approach
to assigning academic work and imposing deadlines on us on very short notice-I believe that is something only instructors can do and not class officials.
Best,
Chin
On Sun, Feb 23, 2014 at 5:47 PM, Armando
Lee <aclee.mdm2014@myapps.aim.edu> wrote:
Please make the 4 slides ppt right away and email me a copy (due tomorrow
AM). Make a hard copy too and submit it to Prof Gavino next class session with
him.
-Arman
On Fri, Feb 21, 2014 at 3:07 PM, Armando
Lee <aclee.mdm2014@myapps.aim.edu> wrote:
Or is the Bureau of Customs your identified stakeholder already?

On Fri, Feb 21, 2014 at 3:06 PM, Armando


Lee <aclee.mdm2014@myapps.aim.edu> wrote:
OK. Who is your major stakeholder in BC?

On Fri, Feb 21, 2014 at 2:32 PM, Khristin


Consunji <kconsunji.mdm2014@myapps.aim.edu> wrote:
Hi Arman,
We're doing a stakeholder analysis of the Bureau of Customs.
Best,
Chin

6. Complainant refused to submit the Stakeholder Analysis of LT6 to Armando


Lee due to her foreknowledge of the fact that Armando Lee had plagiarized
the work of her teammates Rommel Rubiales.

7. In a previous text message exchange on February 13, 2014 Rommel Rubiales


had sent Complainant the following text which she responded to on February
14, 2014:

February 13, 2014 Rommel 11:59 09209507432:
Chin I would like to apologize that I was not able to ask for your permission
when I did the MRR PPT I never meant to bypass our group only good
intentions for our learning team.

February 14, 2014 Complainant 8:47 am 09212549616:
No its fine! Rommel do not worry! I thought your report was great and you
dont need my permission.
8. The text message exchange was referring to the initial draft of the
Powerpoint Presentation for the Concept Notes sent by Rommel Rubiales to
LT6, of which Complainant was a member, as documented by the following
email exchange:



---------- Forwarded message ---------From: rommel rubiales <rkatigbakrubiales@yahoo.com>
Date: Thu, Feb 13, 2014 at 8:55 AM
Subject: Re: Management Research Report Concept Notes
To: "chin.consunji@gmail.com" <chin.consunji@gmail.com>,
"leka.pitoi47@gmail.com" <leka.pitoi47@gmail.com>,
"iqadeer.mdm2014@myapps.aim.edu" <iqadeer.mdm2014@myapps.aim.edu>,
"nguyenthithudong@gmail.com" <nguyenthithudong@gmail.com>,
"ripon_ripon2005@yahoo.com" <ripon_ripon2005@yahoo.com>

I mean the copy of the revised Powerpoint Presentation for our MRR
On , rommel rubiales <rkatigbakrubiales@yahoo.com> wrote:

This is the revised PPT slides, I cited Section 602 of the Tariff and Customs
Code of the Philippines for the function of the Bureau of Customs. Ismeera, this
is a group work.
On Wednesday, February 12, 2014 11:20 PM, rommel rubiales
<rkatigbakrubiales@yahoo.com> wrote:

9. On February 17, 2014 at 12:55 AM, Rommel Rubiales forwarded his notes
to the class in the following email exchange. During this exchange, it is
explicitly clear that Mr. Rubiales submitted his notes ahead of Dr. Armando
Lee, who expressed his admiration for said notes in the following e-mail
exchange which was sent to Doctor Paragua as well as Dean Juan Miguel Luz:








---------- Forwarded message ---------From: Khristin Consunji <kconsunji.mdm2014@myapps.aim.edu>
Date: Tue, Feb 25, 2014 at 6:57 PM
Subject: Fwd: Management Research Report (Concept Notes)
To: Hazel Paragua <hazelparagua@yahoo.com>, Juan Miguel Luz
<jmluz@aim.edu>, Juan Miguel Luz <juanmiguel.luz@gmail.com>

Dear Dr. Hazel and Dean Luz,

Please note the chronology -- Arman did not submit his report until after Rommel
did. I also have earlier emails from Rommel when he gave his draft to our LT for
comments, so I can personally attest to his original authorship.
Best,
Chin
---------- Forwarded message ---------From: Armando Lee <aclee.mdm2014@myapps.aim.edu>
Date: Mon, Feb 17, 2014 at 8:56 AM
Subject: Re: Management Research Report (Concept Notes)
To: Rommel Rubiales <rrubiales.mdm2014@myapps.aim.edu>
Cc: MDM 2014 <MDM2014@myapps.aim.edu>
Rommel,
That's one very good MRR you got there. I like it very much.

-Arman
On Mon, Feb 17, 2014 at 12:55 AM, Rommel
Rubiales <rrubiales.mdm2014@myapps.aim.edu> wrote:




10. On February 24, 2014, Complainant reported plagiarized Concept Notes
Presentation of Class Officer Armando Lee to Professors Ron Chua, Doctor
Paragua and Dean Juan Miguel Luz. While the original email was addressed
to Professor Ron Chua. However, only Doctor Hazel Paragua responded:

---------- Forwarded message ---------From: <hazelparagua@yahoo.com>


Date: Tue, Feb 25, 2014 at 10:57 AM
Subject: Re: Anomalies in Comparison of Concept Notes
To: Khristin Consunji <kconsunji.mdm2014@myapps.aim.edu>, Juan Miguel Luz
<jmluz@aim.edu>, Juan Miguel Luz <juanmiguel.luz@gmail.com>
Dear Chin,

We will look into this case. Thank you for bringing it to our attention.

Dr Paragua


Sent from my BlackBerry 10 smartphone.
From: Khristin Consunji
Sent: Tuesday, February 25, 2014 10:02 AM
To: Hazel Paragua; Juan Miguel Luz; Juan Miguel Luz
Subject: Fwd: Anomalies in Comparison of Concept Notes

Hello,
I am writing to advise pertinent faculty members of Dr. Arman Lee's plagiarism of
Rommel's concept notes for the MRR. Given the immense lack of ethics
displayed by this act, I would recommend that Dr. Lee be removed from his post
as student officer. As per the advice of Dr. Limlingan, I was told to forward this
issue to both of you for your consideration.

Best,
Chin
---------- Forwarded message ---------From: Khristin Consunji <kconsunji.mdm2014@myapps.aim.edu>
Date: Mon, Feb 24, 2014 at 8:12 PM
Subject: Re: Anomalies in Comparison of Concept Notes
To: Ron Chua <rtcmdm2014@gmail.com>
Dear Professor Chua,
After consulting with Dr. Limlingan earlier today, he advised me to forward you
the files for you perusal, to document the alleged similarities. As I noted earlier,
Rommel is still uncomfortable coming forward but I believe that this a serious
academic offense that merits attention. This was something Rommel had spoke
of in confidence but in light of this breach, I believe the class cannot be lead by
an officer such as Dr. Armando Lee who has stolen the intellectual property of
another student.
Best,
Chin
On Mon, Feb 24, 2014 at 5:37 PM, Khristin
Consunji <kconsunji.mdm2014@myapps.aim.edu> wrote:
Dear Sir,
Today, I was recently made aware of a situation pertaining to academic
dishonesty, where a student's concept notes presentation for the MRR was
plagiarized by another student. In order to give due respect to the other student, I
want to exercise utmost discretion regarding this matter -- however, I am
immensely disheartened because the offender is a class officer.
What is the protocol for matters like this?
Best,
Chin
11. On the morning of February 26, 2014, on the steps of the AIM Lobby, Doctor
Paragua had informed Complainant that there was no plagiarism to speak of
as the MRR Powerpoint was merely a pro-forma strategic management
template contrary to the statements of Rommel Rubiales.

12. To be clear, here are the slides that demonstrate significant similarities
between the submissions of Armando Lee and Rommel Rubiales:


Slide
No.
3

Rommels Slides

Armans Slides

Annex

10

13. Clearly, the unmistakable identity and similarity of the slides is not limited to
the text alone, but goes to the very organization and progression of the
intellectual framework behind the work which belies the claim that Doctor
Paragua claims came from a pro-forma template.
14. On the same day Doctor Paragua then referred the case to Dean Juan Miguel
Luz who called Complainant into his office at approximately 11:00 am with a
copy of the MRR Concept Notes that had been run through Turnitin instead of
the plagiarized presentation MRR presentation attached with the e-mails.

15. Dean Luz then addressed Complainant for raising a supposedly false case of
academic dysfunctional behavior whereas Complainant informed Dean Luz
that what she had forwarded was the MRR Concept Notes Presentation.

16. Dean Luz then consulted the MDM Student Handbook as opposed to the AIM
Student Handbook and claimed that since the MRR Concept Notes
Presentation did not constitute an expellable offense in the MDM Handbook,
then the charge of plagiarism did not matter.



17. However, Dean Luz was not aware of the other policies pertaining to
academic dysfunctional behavior since he only consulted the MDM Student
Handbook, as opposed to the AIM Student Handbook.

18. To wit, in the AIM Student Handbook, page 22, under Academic
Dysfunctional Behavior 1(j), Armando Lee was liable under the subsection
plagiarism which is defined as to copy works of others, including works in
the public domain, without proper acknowledgement, citation or
permission.


19. Thus, Doctor Paragua had intentionally and maliciously supplied Dean Luz
with the MRR Concept Notes instead of the plagiarized presentation, in a
clear effort to discredit Complainant to Dean Juan Miguel Luz in blatant favor
of Armando Lee, condoning academic dysfunctional behavior, as
Complainant had copy-furnished the Plagiarized Concept Notes in the
Presentation instead of the MRR Concept Notes that were provided by Doctor
Paragua to Dean Juan Miguel Luz.

20. It is believed that Doctor Paragua abused her position as MDM program
director and her personal relationship with David Zuellig, son of Stephen
Zuellig, chief donor to the AIM Center for Development Management School,
in order to continue harassing Complainant without repercussions from her
direct superior Dean Juan Miguel Luz or other Faculty, or misrepresent the
Complainant.
21. Complainant had also referred the case and the matter to SA Chairman Coen
Damen who was unaware of the protocol for such matters:


---------- Forwarded message ---------From: Khristin Consunji <kconsunji.mdm2014@myapps.aim.edu>
Date: Wed, Feb 26, 2014 at 11:25 AM
Subject: Re: Apologies about earlier today
To: Coen Damen <cdamen.mdm2014@myapps.aim.edu>
Hey Coen,
I went over the situation with Dean Luz and Hazel. They are claiming that since
there was no copying in the official concept notes submission -- just on the
Powerpoints -- then there is no plagiarism to speak of. I think this is ridiculous.
Best,
Chin
On Tue, Feb 25, 2014 at 7:52 PM, Coen
Damen <cdamen.mdm2014@myapps.aim.edu> wrote:
OK, see you tomorrow.

On Tue, Feb 25, 2014 at 6:46 PM, Khristin


Consunji <kconsunji.mdm2014@myapps.aim.edu> wrote:
Hi Coen,
Ok, let's try to meet to talk about this. To be honest, I'm really quite weary of this
whole situation. Arman is very close to Hazel and although it is clearly articulated
in the handbook that any plagiarism of MRR material is an expellable offense, I
am not very confident in her abilities to handle the matter impartially which is why
I consulted with Dr. Limlingan (former Dean) on this issue.
Best,
Chin
On Tue, Feb 25, 2014 at 10:32 AM, Coen
Damen <cdamen.mdm2014@myapps.aim.edu> wrote:
Hi Chin,
Lets have lunch one of these days.
I'm quite stunned by the similarities between the two! (actually I uttered a few
profanities...) I have to check what exactly the role of the SA is in these matters,
as I seem to recall that there is a distinct difference between disciplinary issues
about behavior on campus and academic issues. I'm quite hung over today, this
really doesn't help.... I also hope Rommel is not affected by this.
Cheers,
C.
On Tue, Feb 25, 2014 at 10:06 AM, Khristin
Consunji <kconsunji.mdm2014@myapps.aim.edu> wrote:
Hi Coen,
I don't think we were misreading anything, Arman was way out of line and being
immensely autocratic.
I've already forwarded this plagiarism matter to Professor Luz, Professor Chua
and Hazel. Please just talk to them about it as both Rommel and I are weary of
discussing the issue -- Arman is a master of managing upwards and can attempt
to portray himself as the victim rather than the perpetrator. Please look at these
presentations and then decide for yourself. You will probably be called in as there
will be a disciplinary hearing.

On Tue, Feb 25, 2014 at 10:02 AM, Coen


Damen <cdamen.mdm2014@myapps.aim.edu> wrote:
Hi Chin,
Thank you for discretely informing me about the whole matter. I'm a bit shocked
now... I really hope nothing comes from it (I can't imagine why he would have
done something so profoundly stupid), but its definitely a serious matter and can
have serious consequences. So its good for me to know something is 'cooking',
and just to be absolutely clear: I will always use maximum discretion. If this
matter needs anyone to listen, talk or mediate, know that I am available.
Reading this, I can understand that there are some strong feelings and tensions.
I do think email is usually not the best way to discuss matters, as it is a rather
crude way of communicating (in that a lot of "non-verbal-information" is lost), but I
can understand why you emailed it. I wasn't that happy with the tone of his mail
and the process he chose, I just chose to ignore it, also because I knew that
Armand was already very unhappy with the prof giving him that task. Anyway, I
think he got the point loud an clear, hahaha.
About what is in his powers to do: I don't think we need to go so far as to debate
what exactly are his powers, in fact, I would assume that they are not that
different from each and every classmate. I do think he tried to accommodate
what the prof asked him to do. I don't think he meant to do it in an autocratic way,
just give him at this point at least the benefit of the doubt :-).
Enjoy the day off today, cheers!
Coen.

On Mon, Feb 24, 2014 at 5:19 PM, Khristin


Consunji <kconsunji.mdm2014@myapps.aim.edu> wrote:
Hi Coen,
Sorry about earlier today. What I did not want to say was part of what fueled my
fit of pique was the good doctor had plagiarized something from one of my
teammates in the concept notes for MRR. Please just keep that between the two
of us but I am rightly pissed off. Also, I resent the idea that Arman can just
choose presentations based on his own discretion or assign us work when he
feels like it -- that is overstepping his bounds and I am very quick to point out -rightly so, I might add-- that it is not within his powers to do so.

Please exercise discretion as we may be elevating this matter to a disciplinary


body, depending on how the other student feels.
Best,
Chin

22. Failure to act on the part of Coen Damen and failure to address issues of
Academic Dysfunctional Behavior that are forwarded to the SA or failure to
know and act upon the relevant sections of the Student Handbook for
academic dysfunctional behavior resulted in continued inaction against
offender Armando Lee.
23. On March 3, 2014 Rommel Rubiales texted Complainant the following about
the results for the EMDA Take-Home exam:
Rommel 5:12 pm: Chin we got the 105/100 for EMDA. You answered all the
questions therefore you should get the individual grade of 5.0
Complainant 5:16 pm: Wow! How did you know?

24. Complainant then deferred with the following text message out of modesty
and recognition for teamwork even though Rommel Rubialess statement
was true:

Complainant 5:26 pm: I did not answer all the questions. Ismeera and the
rest helped a lot! Team effort.
25. On the same day, Rommel Rubiales also sent a text to Complainant on March
3, 2014:
Rommel Rubiales 5: 26 pm: I got the copy from Dong. Dr. Arman talked to me
regarding the issue with his MRR Concept Notes.
26. On March 3, 2014, Complainant received a response to the email from
Professor Ron Chua:




---------- Forwarded message ---------From: Ron Chua <rtcmdm2014@gmail.com>

Date: Mon, Mar 3, 2014 at 7:45 AM


Subject: Re: Anomalies in Comparison of Concept Notes
To: Khristin Consunji <kconsunji.mdm2014@myapps.aim.edu>
This is to acknowledge your email and will look into this to determine the proper
course of action.

On Mon, Feb 24, 2014 at 8:12 PM, Khristin


Consunji <kconsunji.mdm2014@myapps.aim.edu> wrote:
Dear Professor Chua,
After consulting with Dr. Limlingan earlier today, he advised me to forward you
the files for you perusal, to document the alleged similarities. As I noted earlier,
Rommel is still uncomfortable coming forward but I believe that this a serious
academic offense that merits attention. This was something Rommel had spoke
of in confidence but in light of this breach, I believe the class cannot be lead by
an officer such as Dr. Armando Lee who has stolen the intellectual property of
another student.
Best,
Chin
On Mon, Feb 24, 2014 at 5:37 PM, Khristin
Consunji <kconsunji.mdm2014@myapps.aim.edu> wrote:
Dear Sir,
Today, I was recently made aware of a situation pertaining to academic
dishonesty, where a student's concept notes presentation for the MRR was
plagiarized by another student. In order to give due respect to the other student, I
want to exercise utmost discretion regarding this matter -- however, I am
immensely disheartened because the offender is a class officer.
What is the protocol for matters like this?
Best,
Chin

27. However, it is unknown exactly what transpired and how the case of
Armando Lee was handled, and what corrective measures (if any) were taken
to address the academic dysfunctional behavior brought forth by
Complainant.

28. Doctor Paraguas treatment of Complainant had been discriminatory from
the outset. To wit, Ms. Paragua once accused Ms. Consunji of trying to use her
social status and position into fooling her classmates to gain an unfair
advantage on February 10, 2014 in class when Ms. Consunji questioned her
if they were allowed to perform research in sectors they had prior
experience with.

29. In a Complaint Filed with Rey Reyes against Doctor Paragua on March 12,
2014 addressing Doctor Paraguas dysfunctional behavior, Complainant had
noted the following:



---------- Forwarded message ---------From: Khristin Consunji <kconsunji.mdm2014@myapps.aim.edu>
Date: Thu, Mar 13, 2014 at 12:22 AM
Subject: Re: Complaint
To: "Reyes, Rey D." <RReyes@aim.edu>

Dear Mr. Reyes,

I have not forwarded a copy of this complaint to Dean Lim yet. To be perfectly
honest, my experience in reporting the situation to Hazel Paragua and Dean
Luz's response have made me reticent to forward this to Dean Lim until I could
gather my thoughts. I spent the past two weeks debating the pros and cons, and
after consulting extensively with my parents and my extended family, I was told
to withdraw from the program if this type of behaviour was condoned in AIM.
However, seeing as I have already committed to the program (both in terms of
time and money), the other option was to see to it that these things never have
the opportunity to repeat themselves.
I would like to note that I had made Dean Luz aware of lack of impartiality on the
part of Ms. Paragua before, particularly with respect to our RAA assignments.
These correspondences can be found on the server. Ms. Paragua had advised
our team that we were not to use prior contacts or work in sectors/industries we
have had prior experience with for our RAA. (I can copy furnish all
correspondences to that effect.) I had made her aware that this was to our
detriment because our learning team contains members of government, two
members of nonprofits, a member of the private sector such as myself and a
member of the church -- in effect, this was to our detriment and it seemed like an
arbitrarily excessive application of the RAA rules.

Upon questioning two previous MDM students Ms. Paragua invited to our class
this afternoon, it was noted that Ms. Lim's team violated the restrictions Ms.
Paragua had enforced by working with a sector a teammate had prior experience
with. Thus, I am questioning the inconsistencies and selective application of
policies on her part with respect to RAA assignments, as her biases could
severely affect the assessment we are meant to carry out.
You are free to forward my correspondences to Dean Lim if the official
submission of the complaint necessitates it.
Best,
Khristine
On Wed, Mar 12, 2014 at 11:55 AM, Reyes, Rey D. <RReyes@aim.edu> wrote:
Hi Khristin,
I am in India right now, back at the office on Tuesday. I noticed that this was
sent only to me. do I presume that Dean Lim does not have a copy of your
complaint yet?
thanks.
Sent from my iPad
On Mar 12, 2014, at 1:19 AM, "Khristin Consunji"
<kconsunji.mdm2014@myapps.aim.edu<mailto:kconsunji.mdm2014@myapps.ai
m.edu>> wrote:
I am enclosing the presentations, both the original from Mr. Rubiales (my
teammate) and Armando Lee. To this date, Armando is given access to the work
of other students (marked and unmarked) due to his position, which creates more
opportunities for dysfunctional academic behaviour in the future. All
correspondences where Mr. Rubiales sent out his original report to the entire
class and Mr. Lee expressed his admiration for said report can be found on the
server. E-mails alerting Hazel Paragua and Dean Luz to the similarities between
these submissions can also be found on the server.
On Wed, Mar 12, 2014 at 1:11 AM, Khristin Consunji
<kconsunji.mdm2014@myapps.aim.edu<mailto:kconsunji.mdm2014@myapps.ai
m.edu>> wrote:
This is a formal complaint I am filing against our program director, Hazel
Paragua, for lack of impartial behaviour in investigating a plagiarism allegation.
On February 24, 2014, I was made aware that our class president Armando Lee
had lifted significant portions of his MRR Concept Notes presentation from my

teammate, Rommel Rubiales. When Ms. Paragua was made aware of this
anomaly and when I spoke to her about it on the morning of February 26, 2014,
she alleged that she did not believe any plagiarism occurred because she
believed that Armando and Rommel had followed a "pro forma strategic
management template" and that the MRR presentation was technically not
subject to plagiarism charges, even if it was submitted to our instructor Professor
Ron Chua. Ms. Paragua then referred the case to Dean Luz who called me into
his office at approximately 11 am and reprimanded me for a supposedly false
plagiarism accusation, with a copy of the MRR concept notes instead of the
plagiarized presentation which was forwarded to him via e-mail on February 24.
As of today, there have been no significant repercussions for Armando Lee for
his plagiarism and such permissiveness from both our program director and the
dean of the management school does not speak well of the academic integrity of
our institution. Furthermore, Ms. Paragua did not exercise sage judgment in
recommending a reprimand for the person who reported the plagiarism instead of
the perpetrator of the plagiarism -- this constitutes dysfunctional and immensely
biased behaviour in any context and will not be tolerated in any form. I would
recommend that Ms. Paragua be recused from any and all assessments I am
involved with, as I am seriously questioning her judgment or lack thereof with
respect to academic matters.
<Management Research Report Rommel K. Rubiales (Concept Notes).pptx>
<MRR_Management Research Report_Lee.pptx>
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30. On March 17, 2014, Complainant received a text message from Rommel
Rubiales:








Rommel 9:23 pm: Chin, goodevening (sic) I dont want you to feel stressed
but our learning teammates have complained to Program Director that we
are dominating the group and I am your bodyguard. I was invited by Dean
Luz to explain the issue this afternoon and I said we are just doing our
part for the benefit of the entire team but it seems like the foreigners are
misinterpreting it.
31. The same night, due to what she felt was an unfair and untrue representation
of what she had contributed to the team, Complainant sent an email to Dean
Luz and Doctor Paragua:

32. Failure to act on said Complaint filed on March 12, 2014 or provide
Complainant with further instructions on how to submit a Formal Complaint
to Human Resources resulted in a progressive escalation of bullying
behaviors, resulting in failure to grant an RAA Extension to Complainants
learning team, despite the fact that it was severely understaffed.

33. Two other students, Ms. Dong Thi Thu Nguyen and Father Richard Ripon
Rozario, had to abstain from the RAA Assessment yet Doctor Paragua
constantly refused Complainants requests for an extension. Ms. Dong
Nguyen Thi Thu and Father Richard Ripon Rozario had to return to their
respective countries. Ms. Dong Nguyen Thi Thus mother suffered from a
stroke and Father Ripons father had died. Yet as the following exchange
demonstrates, Doctor Paragua continually refused to grant extension to
Complainant.
On Tue, Apr 29, 2014 at 11:39 PM, <juanmiguel.luz@gmail.com> wrote: Dear Chin,
This is a rapid appraisal, not an MRR. The assumption is that you will not have complete data given the
short period of time. But given data collected (and you seem to have a lot), you should be able to draw a
profile of the community and its existing challenges.
Do what you can and submit what you have. The deadline cannot be moved given the presentation

schedule on May 1 and 2.


Mike Luz
Sent from my BlackBerry wireless handheld
From: Khristin Consunji <kconsunji.mdm2014@myapps.aim.edu> Date: Tue, 29 Apr 2014 23:05:47
+0800 To: Paragua, Hazel L.<HParagua@aim.edu>; Juan Miguel Luz<juanmiguel.luz@gmail.com>; Juan
Miguel Luz<jmluz@aim.edu>; Hazel Paragua<hazelparagua@yahoo.com> Subject: Request for Extension
of RAA Submission
Dear Doctor Hazel and Dean Luz,
I would like to request if we could extend the deadline for submission of the RAA report. Seeing as our team
is understaffed at the moment (Dong and Father Ripon have family issues to attend to) and given the
amount of fieldwork we had to undertake, it is simply not possible or feasible to have a report of 25-35 pages
due by 1pm tomorrow. Today, Ismeera and I sat down for 15 hours straight with no breaks just to finish up
our data analysis and write the preliminary draft. We are not sure what the other teammates are doing as we
have asked Rommel and Leka to join us to write the report but we have not received submissions or
feedback from them at this date. There was a considerable amount of fatigue involved given all the data we
had to gather in such a short amount of time, as well as the stress of interviewing IDPs for the duration of
our stay. The stresses also caused considerable conflicts in the team as we had a very complex topic to
cover and we needed to give it the consideration it merited.
I understand if this is not feasible or possible, but I hope you understand that we were all working immensely
hard in the field and we barely had time to write after coming back to the resort every day. We also decided
to stay in Estancia on April 27, 2014 to get the technical reports from DENR-EMB, Doctor Rex Sadaba and
the rest of the interagency task force. The informal interviews we conducted with them were key, as they
allowed us to finally understand why the contractor was hired and all the attendant issues. Since fishing is
the main driver of the economy in Estancia and it is the LGUs role to enforce fishing bans 3k from the shore,
unfortunately there is a very high chance that everything from that port is contaminated. We also discovered
that residents were allowed to move back to the shoreline on December 20, 2014 but the benzene ppm on
January 2, 2014 and January 4, 2014 was far above the permissible level. Other issues such as skin
diseases and health issues we saw in the evacuation centers, as well as the considerable amount of bunker
oil left on the shoreline where people are actively fishing are immense causes of concern and it still eludes
us how to articulate the nature of what we observed.
Best, Chin

23. Complainant requested another extension as she had not slept due to the
difficulties of the data-gathering required for the RAA, which Doctor Hazel Paragua
oversees:
Date: Tue, Apr 29, 2014 at 11:21 PM
Subject: Re: Request for Extension of RAA Submission
To: "Consunji, Khristin" <kconsunji.mdm2014@myapps.aim.edu>, "Paragua, Hazel L."
<HParagua@aim.edu>, Juan Miguel Luz <juanmiguel.luz@gmail.com>, "Luz, Juan Miguel"
<JmLuz@aim.edu>






Dear Chin,
We do understand your predicament but the deadline set for the written report (April 30, 1pm)
only allows minimal time for the faculty to review your work before your oral report
presentation. Since your group will be the first to report at 8:30am on May 1, it will be to your
disadvantage if the faculty will not be able to even glance at your paper and base your evaluation
almost entirely on the oral presentation.

Before Dung and Fr Ripon left the country, they promised to participate in your report writing
thru email. Since you were concerned about your group and individual grades and participation
prior to leaving for Estancia, I suggest you get contribution from ALL team members so that not
one or two will be overloaded. Remember that RAA grading is mostly about teamwork and
cooperation. This must be reflected in your output as well.
We can only move your deadline to 5pm tomorrow. We still have to provide all faculty members
with hard copies of your written reports before they all leave AIM. Late papers will be graded
down.
Good luck.
Dr Hazel

---------- Forwarded message ---------From: Khristin Consunji <kconsunji.mdm2014@myapps.aim.edu>


Date: Tue, Apr 29, 2014 at 11:34 PM
Subject: Re: Request for Extension of RAA Submission
To: Hazel Paragua <hazelparagua@yahoo.com>
Cc: "Paragua, Hazel L." <HParagua@aim.edu>, Juan Miguel Luz
<juanmiguel.luz@gmail.com>, "Luz, Juan Miguel" <JmLuz@aim.edu>
Dear Doctor Hazel,
Thank you for your response. Would it be possible to submit our preliminary draft
tomorrow and then the final one at a later date? I understand the need for teamwork but
given the severity of the personal/family issues for Dong and Father Ripon, it has been
difficult to contact them for participation in this report. On the evening of the 27th, there
was also an incident where a teammate simply stated that he did not want to work
anymore, as he had been overtaxed. Unfortunately, these are issues that happen and
they are understandable when everybody is under duress, but this what we have to work
with. Ismeera and I tried calling the other teammates to come in but they have refused,
so we have to factor in the possibility that she and I will have to write this report solely. As
of now, there are roughly 2,000 words and realistically, perhaps another 2,000 can be
produced tomorrow but it is unsure what the quality of the output would be. I would like to
stress that everybody has contributed and everybody has worked very hard -- it is a
collective effort. The team has performed and we performed well. But there's really
nothing left in the tank and we cannot be assured that everything will come together in
less than 24 hours time. If there is a late penalty, perhaps it would be best if we are
aware of it so we can plan for that possibility. This is a good report and we were able to
identify the key gaps -- but as I had joked, I believe we are also in need of some
humanitarian assistance because exposure to these issues while working was very
taxing for us all, psychologically.
Best,
Chin


34. Doctor Paragua claiming that they just have to be fair to the rest of the nine
learning teams who tried to comply by the rules and discriminatory

behavior against Complainant whose team was understaffed constitutes


workplace bullying and harassment, namely, imposing unrealistic deadlines
and tasks and setting Complainant up to fail.


---------- Forwarded message ---------From: <hazelparagua@yahoo.com>


Date: Thu, May 1, 2014 at 6:59 AM
Subject: Re: Resent LT6 RAA Report
To: Khristin Consunji <kconsunji.mdm2014@myapps.aim.edu>, Juan
Miguel Luz <jmluz@aim.edu>, Juan Miguel Luz
<juanmiguel.luz@gmail.com>, Leka Pitoi
<lpitoi.mdm2014@myapps.aim.edu>, "Paragua, Hazel L."
<HParagua@aim.edu>, Lyndon Constantino
<lyndonconstantino@gmail.com>, Ripon Rozario
<rrozario.mdm2014@myapps.aim.edu>, Rommel Rubiales
<rrubiales.mdm2014@myapps.aim.edu>, Dong Nguyen Thi Thu
<nguyenthithudong@gmail.com>, ndong.mdm2014@myapps.aim.edu

Dear LT6,

Please note that your written report is being submitted only at
6:52 AM, May 1. We will have to give your team a corresponding
deduction for being the only team not submitting on time (despite
the extension originally given you). We just have to be fair to the
rest of the nine learning teams who tried to comply with the rules.

Good luck on your presentation.

Dr Hazel


35. Clearly, just to be fair to a severely understaffed team not only constitutes
immense bias but also malicious intent and injurious harm against
Complainant by Doctor Paragua as she does not possess the capacity to
realize the inherent irony in her statements.

36. Failure to grant the extension by Doctor Paragua resulted in Complainants


hospitalization on May 6, 2014 for high fever and exhaustion. Ms. Marlene
Bonnin accompanied Complainant to hospital as Complainant had been sick
for several days after the RAA.


37. Supporting medical documentation was provided to Lyndon Constantino and
Ms. Marlene Bonnin can personally attest to Complainants ill-health prior to
her RAA assignment, as well as after the RAA itself.


38. Failure to grant the extension by Doctor Paragua resulted in Complainants
hospitalization on May 6, 2014 for high fever and exhaustion. Ms. Marlene
Bonnin accompanied Complainant to hospital as Complainant had been sick
and immobile for days.

39. Supporting medical documentation was provided to Program Associate
Lyndon Constantino on May 6, 2014 when Complainant went to AIM to pick
up her EMDA Individual Examination test results.

40. Doctor Paragua knowingly and maliciously abused her position of power and
authority as Program Coordinator to misrepresent truth about Complainant
and harass her continuously, with the intention of maligning her to the rest
of the Institute in the hope of her expulsion.
41. Yet Complainant displays significant academic aptitude and skill, earning her
a place in the Deans List for Module I which clearly demonstrates that
despite Doctor Paraguas continued harassing and bullying efforts at
obstructing Complainants rights to unimpeded learning, Complainant
demonstrated sufficient intellectual prowess and superiority to disprove
Doctor Paraguas repeated unfounded ad hominem attacks.
42. Complainant respectfully prays for the application of the imposable sanctions
against all liable parties under the rules of the Institute.




In the City of Makati, July 1, 2014


Khristine Carissa Consuelo Malig Consunji

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