G.R. No. L-45551 - Angeles vs. Sison

In November 1975, Professor Jose S. Angeles filed an administrative complaint before the Office of the Dean, Gilberto G. Mercado, of the Institute of Technology, FEU, alleging that he was assaulted by two students, Edgardo Picar and Wilfredo Patawaran, on October 20, 1975.

The incident occurred at the Oak Barrel Restaurant in Quiapo, Manila during a birthday party of another professor, Alfonso Bernabe, then Secretary of the Institute of Technology.

Simultaneously, a criminal complaint for assault against a person in authority was initiated in the Office of the City Fiscal of Manila, later amended to include physical injuries.

The criminal proceedings evolved differently: the case against Wilfredo Patawaran was dismissed, while an information for slight physical injuries was filed against Edgardo Picar, which was later dismissed on July 8, 1977, based on an affidavit of desistance stating the incident arose from a “misunderstanding.”

Acting on the complaint, Dean Mercado convened an investigative committee to probe the alleged assault, thereby initiating an administrative investigation.

The private respondents (Picar and Patawaran) questioned the Dean’s authority, arguing that his power to investigate under FEU’s Code of Conduct was confined to acts occurring within the university premises.

Despite the questioning of jurisdiction, the Dean proceeded with the investigation in view of the alleged assault emanating from the professor-student relationship and its impact on school discipline.

On February 13, 1976, the private respondents, with Wilfredo Patawaran represented by his father, Wenceslao Patawaran, filed a complaint in the Court of First Instance (CFI) of Manila seeking a writ of preliminary injunction to stop the administrative investigation.

The respondent judge promptly issued an order restraining the petitioners (Angeles and Mercado) from further conducting the investigation, pending further hearings.

Despite subsequent motions for reconsideration by the petitioners (filed on July 13, 1976) and oppositions by the private respondents, the preliminary injunction order was upheld by the lower court on June 7, 1976, and later denied in reconsideration on October 11, 1976.

The petitioners then moved for summary judgment, arguing that the matter was purely one of law and without factual dispute, and the private respondents manifested their consent on December 8, 1976.

Ultimately, on December 29, 1976, the respondent judge rendered a decision that perpetually enjoined the petitioners from proceeding with the administrative investigation.

The petitioners appealed the lower court decision, challenging several aspects regarding the school’s jurisdiction and authority over its students.

They argued that the administrative investigation was within the powers granted by the FEU’s rules and the Manual of Regulations for Private Schools.

The petitioners contended that the investigation was warranted because the alleged misconduct adversely affected the moral character and the discipline of the academic community, notwithstanding that the incident occurred off-campus and outside regular school hours.

They raised specific claims regarding the improper application of the Service Manual for Public Schools as analogous to FEU’s rules, and questioned whether pending or dismissed criminal charges should affect the administrative investigation.

Whether a school, through its duly authorized representative, possesses jurisdiction to investigate and discipline its student(s) for misconduct committed outside of its physical premises and beyond school hours.
Whether the rules and regulations under the Manual of Regulations for Private Schools and the FEU Code of Conduct can be properly applied to an incident that occurred off-campus.
Whether the dismissal or pendency of criminal charges against the student respondents should preclude an administrative investigation by the school.
Whether the respondent judge erred in interpreting the scope of the term “school discipline” and in extending the investigation’s reach to include acts committed outside the campus.