Case Digest (G.R. No. 127930)
Facts:
In Miriam College Foundation, Inc. v. Hon. Court of Appeals, Jasper Briones, Jerome Gomez, Relly Carpio, Elizabeth Valdezco, Jose Mari Ramos, Camille Portugal, Joel Tan and Gerald Gary Renacido, G.R. Nos. 127930 and 119027, December 15, 2000, the Supreme Court First Division, Kapunan, J., writing for the Court, resolved a dispute arising from disciplinary sanctions imposed on campus journalists and contributors to the college paper and literary magazine.Respondent students (members of the editorial board and contributors to the Chi-Rho broadsheet and the anthology Ang Magasing Pampanitikan ng Chi-Rho) published the September–October 1994 issues, whose contents several members of the college community and a concerned grade-school pupil characterized as obscene, vulgar, or otherwise injurious to young readers. After complaints, the Chair of the Miriam College Discipline Committee notified the student editors/contributors by letter dated November 4, 1994, that they were the subject of inquiry for alleged violations of the student handbook and set an initial hearing.
The students declined to submit written answers and instead asserted that jurisdiction lay with the Department of Education, Culture and Sports (DECS) Regional Office under Rule XII of DECS Order No. 94, Series of 1992, and cited Republic Act No. 7079 (the Campus Journalism Act) and its implementing rules. The Discipline Committee nevertheless proceeded ex parte. The Disciplinary Board subsequently imposed sanctions ranging from withholding graduation privileges and suspension to dismissal and expulsion on eleven students; five received lesser sanctions that the students later did not include in their further petitions.
Five of the punished students filed a petition for prohibition and certiorari with preliminary injunction/restraining order before the Regional Trial Court (RTC), Quezon City. On January 17, 1995, the RTC denied a temporary restraining order (TRO). On February 10, 1995, the RTC granted a writ of preliminary injunction preventing enforcement of expulsion/dismissal against five students and readmission restrictions against all eleven, subject to bond. On February 22, 1995, however, the RTC dismissed the petition and recalled prior orders, effectively allowing the disciplinary sanctions to stand.
The students (excluding Deborah Ligon, Imelda Hilario and Daphne Cowper) sought relief in the Supreme Court by petition for certiorari and prohibition (docketed as G.R. No. 119027). The Supreme Court referred the case to the Court of Appeals (CA), which on May 19, 1995 issued a TRO enjoining Miriam College from enforcing the dismissal/suspension orders; on September 26, 1996 the CA granted the students’ petition and declared the RTC order of February 22, 1995 and the suspensions/dismissals void. Miriam College then brought the matter to the Supreme Court (docketed as G.R. No. 127930). The Court limited its review to four issues: m...(Subscriber-Only)
Issues:
- Is the controversy moot or academic?
- Did the Regional Trial Court have jurisdiction to entertain the petition for certiorari filed by the students?
- Does petitioner Miriam College have the power to suspend or dismiss the respondent students?
- Does petitioner Miriam College have jurisdiction to hear and decide the complaints against the students, or does jurisdiction lie exclusively with the DECS Regional Office...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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