Title
Ateneo De Manila University vs. Capulong
Case
G.R. No. 99327
Decision Date
May 27, 1993
Ateneo students expelled for hazing resulting in a death; Supreme Court upheld dismissal, affirming due process and academic freedom.
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Case Digest (G.R. No. 99327)

Facts:

  1. Background of the Case:

    • The case involves the expulsion of several students from Ateneo de Manila University (Ateneo Law School) for their participation in hazing activities during the initiation rites of the Aquila Legis fraternity in February 1991.
    • The hazing resulted in the death of Leonardo "Lennie" Villa, a first-year student, and the hospitalization of another student, Bienvenido Marquez, due to severe physical injuries.
  2. Investigation and Charges:

    • On February 11, 1991, Dean Cynthia del Castillo formed a Joint Administration-Faculty-Student Investigating Committee to investigate the incident.
    • The students involved were placed on preventive suspension and were required to submit written statements. They failed to comply initially but later requested copies of the charges and evidence.
    • On February 14, 1991, the committee found a prima facie case against the students for violating Rule No. 3 of the Ateneo Law School Rules on Discipline, which prohibits hazing.
  3. Disciplinary Proceedings:

    • A Disciplinary Board was created on February 20, 1991, to hear the charges. The students were informed of the charges and given the opportunity to respond.
    • The students requested a postponement of the hearing and sought access to the evidence against them. The Board denied their request for cross-examination of witnesses, citing the summary nature of the proceedings.
    • On March 9, 1991, the Board found the students guilty of hazing, either by active participation or acquiescence. The penalty of dismissal was recommended, but the final decision was left to the University President, Fr. Joaquin Bernas.
  4. University President’s Decision:

    • On March 10, 1991, Fr. Bernas upheld the Board’s findings and imposed the penalty of dismissal on the students, citing the gravity of the offense and its incompatibility with the values of Christian education.
  5. Legal Proceedings:

    • The students filed a petition for certiorari, prohibition, and mandamus with the Regional Trial Court (RTC) of Makati, alleging a lack of due process in their dismissal.
    • The RTC issued a temporary restraining order (TRO) preventing the students' dismissal and ordered their reinstatement.
    • The University challenged the RTC’s decision before the Supreme Court, arguing that the students were afforded due process and that the expulsion was justified under the principle of academic freedom.

Issue:

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Ruling:

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Ratio:

  1. Due Process in School Disciplinary Proceedings:

    • The Court reiterated that disciplinary proceedings in academic institutions need not adhere to the strict requirements of judicial proceedings. The minimum standards of due process, as outlined in Guzman v. National University, were satisfied:
      • The students were informed of the charges.
      • They were given the opportunity to answer the charges with the assistance of counsel.
      • They were informed of the evidence against them.
      • They were allowed to present evidence in their defense.
      • The evidence was duly considered by the investigating body.
  2. Academic Freedom:

    • The Court emphasized that academic freedom includes the right of educational institutions to establish and enforce disciplinary rules. This freedom encompasses the authority to determine who may be admitted to study and to impose sanctions for violations of school regulations.
    • The University’s decision to expel the students was justified as it was based on the students’ participation in hazing, which is contrary to the institution’s moral and educational standards.
  3. Proportionality of the Penalty:

    • The Court found that the penalty of dismissal was proportionate to the offense, given the severe consequences of the hazing incident, including the death of a student. The University’s decision was deemed reasonable and free from malice.
  4. Exception to the Doctrine of Exhaustion of Remedies:

    • The Court ruled that the University was not required to file a motion for reconsideration before the RTC, as the case involved a question of law (i.e., whether the students were afforded due process).
  5. Temporary Restraining Order:

    • The Court upheld the issuance of a TRO to prevent the students’ reinstatement, as their immediate return to the University would undermine the school’s authority and academic freedom.

Conclusion:

The Supreme Court affirmed the University’s decision to expel the students, holding that the disciplinary proceedings complied with due process and that the penalty of dismissal was justified under the circumstances. The Court reinforced the principle of academic freedom, emphasizing the right of educational institutions to enforce disciplinary rules and maintain moral and academic standards.


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