G.R. No. L-40779 - Garcia vs. Faculty Admission Committee

In summer 1975, petitioner Epicharis T. Garcia was admitted by respondent Faculty Admission Committee of the Loyola School of Theology to take two theology courses for credit, free of charge.
The admission did not include acceptance into a degree program because only the Assistant Dean of the Ateneo de Manila University Graduate School could grant formal admission to an M.A. in Theology.

On May 30, 1975, Father Antonio B. Lambino, chairman of the Faculty Admission Committee, informed petitioner that the faculty voted to bar her from re-admission for the 1975–76 first semester.
The reasons stated in the May 19, 1975 letter included the faculty’s view that her “frequent questions and difficulties” were not always pertinent and slowed class progress, making her future advisability in the seminary “very questionable.”

From June 2–5, 1975, petitioner sought a compromise with school authorities (including Fr. Pedro Sevilla, Director) to permit her continued studies; the efforts failed and the faculty’s decision was deemed final.
Petitioner inquired at UST Ecclesiastical Faculties and learned she could enroll only as a special student—requiring four to five additional years to complete both philosophy prerequisites and the theology degree—whereas Loyola’s program would have taken two years.

Petitioner filed a petition for writ of mandamus in the Supreme Court to compel Loyola to admit her for the first semester of 1975–76, including cross-enrollment beyond the June 11 registration deadline and accreditation of any UST units.
She alleged her barring lacked legal basis, cited no violation of school regulations or misconduct, and argued her academic welfare was jeopardized.

Respondent explained Loyola School of Theology is a seminary enjoying constitutional academic freedom, collaborating with Ateneo for degree conferral, and possessing discretion over student admission based on intellectual, personality, and character considerations.
The Committee asserted there was no clear duty to admit petitioner into a degree program, and mandamus could not override institutional autonomy; alternative non-judicial remedies were available but not exhausted.

Whether petitioner has a clear legal right, as opposed to a mere privilege, to continued admission in Loyola School of Theology’s graduate program in theology.
Whether a writ of mandamus is the proper remedy to compel admission to a seminary that, under constitutional academic freedom, exercises discretionary control over its student body.