Case Digest (G.R. No. L-68288) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 68288 decided on July 11, 1986, petitioners Diosdado Guzman, Ulysses Urbiztondo, and Ariel Ramacula, students of National University (NU), sought a writ of mandamus and injunctive relief to compel respondent NU and its President, Domingo L. Jhocson, to allow their re-enrollment for the 1984–1985 semester. On August 7, 1984, they filed a petition alleging that the University refused to re-enroll them because of their participation in peaceful student demonstrations on campus, effectively imposing the penalty of expulsion without cause, without notice or hearing, in violation of due process. In its Comment of September 24, 1984, NU contended that failure to enroll was petitioners’ own fault: Urbiztondo purportedly attempted late registration, Guzman had poor academic performance and faced pending criminal and civil charges for campus property damage, and Ramacula allegedly disrupted classes without permit. NU further argued that petitioners forfeited any right to enrol Case Digest (G.R. No. L-68288) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petitioners’ allegations
- Diosdado Guzman, Ulysses Urbiztondo, and Ariel Ramacula, students of National University (NU), were refused re-enrollment on grounds of their “participation in peaceful mass actions” within university premises.
- They claimed NU’s action was a continuation of hostility to student constitutional rights (citing Rockie C. San Juan vs. NU, G.R. No. 65443) and deprived them of due process (citing Berina v. Philippine Maritime Institute).
- Respondents’ defenses
- National University and President Domingo L. Jhocson asserted petitioners’ own faults:
- Urbiztondo allegedly sought re-enrollment only on July 5, 1984 (after enrolment closed).
- Guzman’s poor academic showing was due to leading class boycotts; he faced criminal charges for malicious mischief (MTC Manila Crim. Case No. 066446) and a civil suit for campus damage (RTC Manila Civil Case No. 8320483).
- Ramacula likewise led or participated in disruptive activities without permit, flouting a Court resolution of November 23, 1983.
- Respondents further argued petitioners were not in good scholastic standing, had forfeited any privilege to enroll, and semester-based enrollment could not be compelled post-deadline.
- Procedural history
- August 14, 1984: Court required respondents’ comment and granted a preliminary mandatory injunction, directing NU to allow enrollment “without prejudice to any disciplinary proceeding.”
- Petitioners replied, disputing late enrollment claims and maintaining their constitutional freedoms were not curtailed.
- November 23, 1984: Court gave due course to the petition, treated the comment as answer, and required memoranda.
Issues:
- Whether National University lawfully refused re-enrollment of petitioners, effectively imposing expulsion without cause or due process.
- Whether respondents observed procedural due process as mandated by the Education Act of 1982 and the Manual of Regulations for Private Schools before denying enrollment.
- What minimum procedural safeguards are required in student disciplinary proceedings.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)