G.R. No. 85839 - Licup vs. University of San Carlos

Tuition Fee Increase: In April 1988, the University of San Carlos (USC) announced a 9% increase in tuition and other school fees for the 1988-1989 academic year. This increase was justified as necessary to comply with R.A. No. 6640, which mandated a salary increase of P11.00 per day for teachers and non-academic personnel earning below P100.00 daily.

Student Protest: Student leaders Emmanuel S. Licup, Noel F. Tabasa, and Joel Marc Cairo led protests against the tuition fee hike. They conducted research and claimed that USC could increase teacher salaries without raising tuition fees. Despite their efforts to negotiate with USC officials, the university refused to roll back the fee increase.

Mass Demonstrations: The student leaders organized mass protests, including blockades at the university entrances and exits, and displayed posters and wall statements demanding a rollback of the fee increase. USC officials, including Fr. Gregorio Favia, SVD, issued memoranda prohibiting the student leaders from campaigning against the fee increase inside classrooms.

Administrative Action: USC President Fr. Roderick Salazar, Jr., SVD, initiated administrative actions against the student leaders for alleged violations of university rules. A Formal Inquiry Committee was formed to investigate the matter. The student leaders questioned the impartiality of the committee and the validity of the university handbook, which they claimed was issued without student government consultation.

Committee Findings: The Formal Inquiry Committee found Licup, Tabasa, and Cairo guilty of the charges and recommended non-readmission for the second semester of the 1988-1989 academic year. The Disciplinary Board upheld this decision, and the students were barred from enrolling in the university.

Appeal to DECS: The students appealed to the Department of Education, Culture, and Sports (DECS), but the Regional Director stated that DECS had no authority over the case and suggested they file a reconsideration with the USC President. The students, believing this would be futile, filed a petition for certiorari with the Supreme Court.

Petitioners' Claims: The students argued that their protest was peaceful, that they were denied due process, and that the penalty of non-readmission was excessive. They also claimed that their property rights were violated and that the investigation was biased.

Respondents' Defense: USC maintained that the tuition fee increase was necessary and lawful, that the protests were disruptive and violent, and that the investigation was fair and impartial. They also pointed out that some of the petitioners had academic deficiencies, which justified their non-readmission.

Due Process: Whether the petitioners were denied due process in the administrative investigation conducted by USC.
Fairness of Investigation: Whether the investigation was impartial and fair, given the petitioners' allegations of bias.
Proportionality of Penalty: Whether the penalty of non-readmission was excessive and disproportionate to the alleged violations.
Academic Freedom: Whether USC's actions were justified under its academic freedom to maintain discipline and order within the institution.
Right to Education: Whether the petitioners' right to education was violated by their non-readmission.