Case Digest (G.R. No. L-15127) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Emeterio Cui v. Arellano University (112 Phil. 135, G.R. No. L-15127, May 30, 1961), plaintiff-appellant Emeterio Cui began his preparatory law studies at Arellano University prior to the 1948–1949 school year. He then enrolled in Arellano’s College of Law from 1948–1949 through the first semester of his fourth year. During this time, he received merit-based scholarship grants that covered his semestral tuition and were refunded after each term, amounting to a total of P1,033.87. When his uncle, Dean Francisco R. Capistrano, resigned from Arellano to head the College of Law of Abad Santos University, Cui likewise transferred to Abad Santos for his final semester without paying outstanding tuition, relying on the scholarship refunds. Upon graduating from Abad Santos, Cui needed his Arellano transcripts to sit for the 1953 Bar Examinations. Arellano refused to issue them unless he repaid the P1,033.87 previously refunded. Under protest, Cui paid the amount to obtain his records Case Digest (G.R. No. L-15127) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Course of Study
- Emeterio Cui enrolled in preparatory law and the College of Law of Arellano University for school years 1948–1949 through first semester of the fourth year.
- Francisco R. Capistrano, Cui’s maternal uncle, served as Dean of Arellano University’s College of Law until his departure to Abad Santos University, after which Cui transferred and completed his last semester there.
- Scholarship Grants and Tuition Refunds
- Cui received merit‐based scholarships each semester, entitling him to a full refund of tuition fees at semester’s end.
- From first semester up to and including first semester of his fourth year, Cui paid then received back a total of ₱1,033.87.
- Contractual Waiver and Release of Records
- Upon each scholarship grant, Cui signed a waiver: he would not transfer without refunding the cash value of his scholarships.
- On August 16, 1949, Director of Private Schools issued Memorandum No. 38, s. 1949, declaring that scholarship refunds may not be conditioned on student retention or be charged upon transfer.
- Arellano University received the memorandum but refused to release Cui’s transcripts unless he repaid ₱1,033.87; Cui, needing the records for the 1953 bar exam, paid under protest.
- Procedural History
- Cui filed suit to recover ₱1,033.87 plus moral damages (₱2,000), exemplary damages (₱500), attorney’s fees (₱2,000), and litigation expenses (₱500).
- Arellano University answered, asserting the waiver’s validity, attacking the memorandum’s binding effect, and counterclaiming ₱10,000 damages plus ₱3,000 attorney’s fees.
- The Court of First Instance upheld the waiver as valid, deemed the memorandum advisory only, absolved Arellano University of liability, dismissed Cui’s claim with costs against him, and dismissed the counterclaim for lack of proof.
Issues:
- Whether the contractual provision waiving Cui’s right to transfer without refunding scholarship cash is valid or void as contrary to public policy.
- Whether Memorandum No. 38, s. 1949 of the Director of Private Schools is mandatory and binding on private institutions and affects the enforceability of the waiver.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)