Case Digest (G.R. No. 163429) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On September 28, 2007, the University of the Philippines (UP) filed seven formal disciplinary charges before the Student Disciplinary Tribunal (SDT) against Ariel Paolo A. Ante and co-accused Marcelino G. Veloso III, Keefe Dela Cruz, and Armand Lorenze V. Sapitan, in connection with the fatal hazing of Chris Anthony Mendez allegedly by the Sigma Rho Fraternity. The charges included participation in hazing activities, abandonment of the victim in hospital, failure to report to authorities, and non-compliance with the Vice Chancellor for Student Affairs’ directive to provide information. Ante answered, requested documentary evidence and tribunal member details, and moved to quash the charges on the ground that no valid preliminary inquiry had been conducted “by any member of the SDT” as required under Section 1, Rule III of the UP Revised Rules and Regulations Governing Fraternities, Sororities and Other Student Organizations. SDT denied his requests and omnibus motion on January Case Digest (G.R. No. 163429) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner: Ariel Paolo A. Ante (Ante)
- Respondents: University of the Philippines Student Disciplinary Tribunal (SDT) and University of the Philippines (UP)
- Formal Charges and Underlying Incident
- Seven disciplinary actions filed on September 28, 2007 against Ante, Marcelino G. Veloso III, Keefe Dela Cruz, and Armand Lorenze V. Sapitan for alleged hazing activities leading to the death of Chris Anthony Mendez
- Accusations included participation in hazing, abandonment of Mendez in the hospital, failure to inform authorities, and non-compliance with UP directives
- Proceedings Before the SDT
- Ante’s answer with request for production of documents, challenges to the validity of the preliminary inquiry under UP Rules Governing Fraternities, and motions for recusals and juror information
- SDT denied all requests and, in January 2008 orders, upheld the preliminary inquiry as valid “through the means, act, agency, or instrumentality” of any SDT member
- Ante filed an omnibus motion seeking quashal of formal charges and inhibition of SDT members on grounds of prejudgment; SDT denied the motion and refused reconsideration
- Petition for Certiorari and Trial Court Ruling
- On March 6, 2008, Ante filed a petition for certiorari and prohibition with the Quezon City RTC, challenging the preliminary inquiry’s validity and claiming due process violations
- RTC Decision dated November 19, 2009 granted the petition, declared SDT proceedings null and void for grave abuse of discretion in conducting the inquiry through the University Prosecutor
- Court of Appeals Ruling
- Respondents appealed; on October 6, 2015, the CA reversed the RTC, holding the preliminary inquiry validly conducted by SDT members and finding no evidence of prejudgment
- Ante’s motion for reconsideration was denied on September 27, 2016, prompting the present petition for review on certiorari
Issues:
- Validity of Preliminary Inquiry
- Whether the SDT complied with Section 1, Rule III of the UP Revised Rules and Regulations Governing Fraternities requiring a preliminary inquiry “by any member of the SDT”
- Due Process and Prejudgment
- Whether SDT’s finding of a prima facie case constituted prejudgment and violated Ante’s right to due process
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)