Case Digest (G.R. No. 238762)
Facts:
In Ateneo de Manila University et al. vs. Capulong et al. (G.R. No. 99327, May 27, 1993), petitioners Ateneo de Manila University, Fr. Joaquin G. Bernas, S.J. (University President), Dean Cynthia Roxas-del Castillo, members of the Joint Administration-Faculty-Student Investigating Committee and Disciplinary Board moved to expel eight law students—Zosimo Mendoza, Jr., Adel Abas, Ernest Montecillo, Amado Sabban, Joseph Lledo, Santiago Ranada III, Jude Fernandez, and Dalmacio Lim, Jr.—for violating Rule No. 3 of the Ateneo Law School Rules on Discipline, which prohibits hazing. On February 8–10, 1991, the Aquila Legis fraternity’s initiation rites resulted in the death of freshman Leonardo “Lennie” Villa and serious injury to another neophyte. The University convened successive bodies: a Joint Committee (Feb. 11), a Disciplinary Board (Feb. 20), and a Special Board (March 5), each affording the students notice, opportunity to answer, assistance of counsel, and summary hearings. OnCase Digest (G.R. No. 238762)
Facts:
- Background and Precedent
- In 1975, petitioner challenged denial of admission to Loyola School of Theology. SC dismissed mandamus for lack of clear duty, invoking academic freedom.
- Eighteen years later, Ateneo de Manila University respondents seek re-admission after prior enrollment and disciplinary expulsion for hazing.
- Hazing Incident and Initial Investigation
- February 8–10, 1991: Aquila Legis fraternity initiation rites at Ateneo Law School resulted in the death of neophyte Leonardo Villa and hospitalization of another.
- February 11, 1991: Dean Cynthia del Castillo created a Joint Administration-Faculty-Student Investigating Committee; respondents placed on preventive suspension and ordered to submit written statements within 24 hours.
- Disciplinary Proceedings
- February 14, 1991: Committee found a prima facie violation of Rule No. 3 (hazing) after written statements and witness testimonies; respondents required to answer formal charges by February 18.
- February 20, 1991: Dean formed a Disciplinary Board; respondents informed of charges, evidence, and deadline to file answers by February 22.
- March 2, 1991: Summary hearing held; respondents informed of limited procedural rights under Guzman v. National University; penalty recommendation deferred to University President.
- Decisions and Court Actions
- March 9–10, 1991: Disciplinary Board found respondents guilty; President Fr. Joaquin Bernas imposed dismissal from the University.
- March 18, 1991: Two students (Abas, Mendoza) excluded pending separate investigation; respondents filed certiorari, prohibition, and mandamus before RTC Makati alleging lack of due process. Temporary restraining order issued.
- May 17–21, 1991: RTC Judge Capulong ordered respondents’ readmission and special exams; Special Board dismissed Abas and Mendoza; SC issued TRO enjoining enforcement of RTC order.
Issues:
- Whether Ateneo de Manila University, under its constitutional academic freedom, may expel students pursuant to its disciplinary rules and moral standards.
- Whether respondents were afforded procedural due process in the disciplinary proceedings leading to their dismissal.
- Whether the penalty of dismissal was proper and proportionate under the circumstances.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)