G.R. No. L-56180 - Ateneo De Manila University vs. Court of Appeals

On December 12, 1967 at about 5:15 PM in Cervini Hall cafeteria, Juan Ramon Guanzon (1st-year student and boarder) allegedly cursed and slapped waitress Carmelita Mateo after she told him to wait for his siopao.
Mateo filed a letter-complaint dated December 13, 1967 to Rev. William Welsh, S.J., Chairman of the Board of Discipline, recounting Guanzon’s profanity, threats, and physical assault, witnessed by boarders who intervened.

Rev. Welsh conducted a preliminary inquiry by interviewing Guanzon’s companions, finding probable cause (Exhs. 5, 6, 7, 9).
A memorandum dated December 16, 1967 was sent to Board members (Exh. 8). Notice of the December 19, 1967 hearing was posted and personally communicated to Guanzon, who appeared, admitted the act, and asked to be excused for Christmas break.
The Board of Discipline, Dean of Arts and Sciences, and University President unanimously affirmed Guanzon’s dismissal (Exhs. 12, 13, 21-A). A motion for reconsideration by the Student Council was denied.
Before execution, Guanzon applied for and was granted honorable dismissal on January 8, 1968 (Exh. 3). His tuition refund for the second semester was arranged by his father.

Parents Romeo G. Guanzon and Teresita Regalado sued Ateneo in the CFI of Negros Occidental, claiming lack of due process and seeking P50,000 moral damages, P92 actual damages, attorney’s fees, and costs.
The trial court ruled for the Guanzons and awarded damages. On appeal, the CA initially reversed and dismissed the complaint, but on motion for reconsideration, a special division of five reinstated the trial court’s decision for lack of due process.

Due process was observed in the disciplinary proceedings.
The parents’ civil suit did not violate finality or exhaustion of administrative remedies.
The CA’s findings suffered grave abuse of discretion and contradicted evidence.

The petition challenged the CA’s reliance on administrative and trial court findings and invoked exceptions to deference when fact-findings are unsupported, speculative, or vitiated by grave abuse.

Whether Ateneo accorded Juan Ramon Guanzon and his parents due process in the disciplinary proceedings.
Whether the parents’ filing of a civil damages suit violated the principles of finality of administrative action or exhaustion of administrative remedies.
Whether the Court of Appeals’ findings and conclusions were tainted by grave abuse of discretion, were conflicting, or contrary to the evidence.