Case Digest (G.R. No. 99327)
Facts:
Ateneo de Manila University v. Capulong, G.R. No. 99327, May 27, 1993, the Supreme Court En Banc, Romero, J., writing for the Court.The petitioners are Ateneo de Manila University, its President Father Joaquin G. Bernas, S.J., Dean Cynthia Roxas-Del Castillo, and members of the Law School Disciplinary Board and Special Board; the respondents are Hon. Ignacio M. Capulong, Presiding Judge of the RTC–Makati, Branch 134, and several law students who were dismissed by the University after a fraternity initiation in February 1991. The private respondents (students) were charged with violating Rule No. 3 of the Ateneo Law School Rules on Discipline (hazing) after the initiation rites of the Aquila Legis fraternity on February 8–10, 1991, which resulted in the death of first-year student Leonardo H. Villa and serious injury to another neophyte.
On February 11, 1991 Dean del Castillo convened a Joint Administration–Faculty–Student Investigating Committee and required written statements; several students were placed on preventive suspension. After receiving statements and hearing witnesses, the investigating committee on February 14 found a prima facie case. A Disciplinary Board composed on February 20 heard the charges, conducted summary proceedings (noting Guzman v. National University as guidance), and on March 9/10, 1991 found the students guilty and referred the penalty to University Administration. President Bernas accepted the factual findings and, on March 10, 1991, imposed dismissal on the respondents (with later exclusion and separate investigation of two students, Abas and Mendoza).
On March 18, 1991 several of the students filed a petition for certiorari, prohibition and mandamus with prayer for TRO and preliminary injunction in the RTC–Makati, alleging denial of due process; a TRO initially issued on March 18. After various procedural developments (the TRO’s lapse on April 7, creation of a Special Board to investigate Abas and Mendoza, respondents’ supplemental petition, and Judge Capulong’s actions), on May 17, 1991 the trial court ordered reinstatement of the students, directed special examinations, and required a bond of P50,000; the Special Board nevertheless on May 20, 1991 again imposed dismissal on Abas and Mendoza, and a preliminary injunction was issued on May 21 upon posting of bond.
Petitioners filed a special civil action under Rule 65 (certiorari) in the Supreme Court seeking to set aside the RTC order reinstating the students; the Cou...(Subscriber-Only)
Issues:
- Did the RTC–Makati commit grave abuse of discretion in ordering the reinstatement of the students such that certiorari under Rule 65 lies?
- Were the respondent students denied procedural due process in the University’s disciplinary proceedings?
- Was the imposition of the penalty of dismissal by the University proper and reasonab...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)