Hulidap as a governance pattern: How silent penalty building weakens small schools
In Tagalog, huli means “to catch” or “to be caught.” When fused with the English word holdup, it gives rise to the term “hulidap”—a sharp, street-level word that captures the experience of being technically “caught,” not to correct wrongdoing, but to be cornered into penalties, payments, or compliance that feel less like regulation and more like an ambush.
It now describes a pattern that many small institutions know far too well: authorities silently allow minor lapses to accumulate, then later present these as grounds for large, destabilizing penalties. It is a system that punishes rather than guides, and it is quietly reshaping the landscape for small schools across the country.
This critique does not accuse any specific agency of misconduct. Instead, it examines a structural pattern visible across multiple regulatory bodies such as the BIR, SEC, SSS, Pag-IBIG, PhilHealth and local governments. What many small schools experience is not the result of isolated error. It is the predictable outcome of a regulatory culture that equates silence with efficiency and penalties with performance.
Small private schools operate under severe resource constraints. In many rural and low-income communities, a single administrator handles enrollment, finances, reporting, facilities management and even student affairs.
When one person is doing the work of an entire department, compliance errors are not evidence of neglect. They are evidence of unrealistic expectations. Yet the regulatory environment treats these institutions as if they had the same compliance capacity as large corporations with legal teams and dedicated accountants.
This mismatch produces hulidap-like scenarios. Requirements change without notice. Guidelines are not communicated in accessible formats. Early reminders are absent. Minor errors, such as using an outdated form or missing a filing deadline, go unaddressed for months or years.
Then, unexpectedly, the school receives a notice containing accumulated penalties that could have been prevented through simple guidance. The penalties accrue quietly, but the impact is loud and destabilizing.
The BIR’s use of Letters of Authority illustrates this dynamic. While LOAs are legitimate instruments of tax enforcement, the absence of pre-audit communication makes them feel like sudden ambushes to small institutions. Issues that could have been resolved early are instead weaponized through silence.
Renewing a mayor’s permit subjects schools to a maze of offices where old lapses reappear, requirements shift and penalties emerge without explanation. Even social protection agencies, whose mandates emphasize welfare, impose rigid penalties when institutions face temporary cash flow difficulties. Without options for restructuring or assistance, penalties become indistinguishable from indifference.
The consequences for schools go beyond administrative inconvenience. When a small school is forced to divert funds to settle accumulated penalties, it often means delaying teacher salaries, postponing building repairs, cutting back on learning materials, or scaling down student support programs.
In more severe cases, the school may be pushed toward closure. When this happens, a community loses more than an institution. It loses access to education, stability and opportunity.
What makes the situation more troubling is the pretense of fairness. Uniform requirements are imposed on institutions with profoundly unequal capacities. A corporation with a full compliance team can respond quickly to regulatory demands.
A small school with a part-time bookkeeper cannot. Treating these institutions as if they were equal is not fairness. It is structural injustice, because uniform treatment produces unequal outcomes.
If government agencies genuinely aim to strengthen the education sector, a shift in regulatory culture is needed. Penalties should not be the first or default response. Agencies can adopt practices that emphasize development instead of punishment.
These include proactive orientations, clear and updated guidelines, automatic reminders before deadlines, transparent dashboards showing compliance status, differentiated requirements based on institutional capacity and independent hotlines that can address misuse of authority.
The purpose of regulation is not to generate fear or revenue. It is to guide institutions toward responsible, ethical and sustainable operation. The culture of hulidap emerges where guidance is absent and silence is used as a tool for penalty building. For small community-serving schools, this culture is not merely inconvenient. It is existential.
A strong and resilient education system requires governance that treats schools as partners, not targets. Compliance should uplift, not entrap. Regulation should help institutions succeed, not lie in wait for them to fail.
If the state wants an education sector capable of supporting national development, then regulatory systems must be grounded in fairness, clarity and compassion. The health of our schools depends on it.
--
Levi “Madam Chair” E. Elipane ([email protected]) is a professor and deputy dean of the College of Advanced Studies of the Philippine Normal University. Arlyne “Madam Ate” C. Marasigan ([email protected]) is a professor at the College of Advanced Studies and a fellow at the Educational Policy Research and Development Office of the Philippine Normal University. The views expressed here are those of the authors and do not necessarily reflect the official position of the Philippine Normal University.
- Latest
