Case Digest (G.R. No. 56169) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Miriam College Foundation, Inc. v. Court of Appeals, G.R. No. 127930, December 15, 2000, petitioner Miriam College challenged the Court of Appeals’ reversal of its disciplinary sanctions against student–journalists. In September–October 1994, the campus newspaper *Chi-Rho* and literary magazine *Ang Magasing Pampanitikan ng Chi-Rho* published allegedly “obscene,” “indecent,” and “vulgar” content, including a Tagalog fiction story “Kaskas” by Gerald Gary Renacido and several erotic poems and illustrations by Jerome Gomez, Relly Carpio, Belle Campanario, and others. On November 4, 1994, the College’s Discipline Committee, chaired by Dr. Aleli Sevilla, notified members of the editorial board—including Jasper Briones (Editor-in-Chief), Jerome Gomez (Associate Editor), Deborah Ligon (Business Manager), Imelda Hilario (News Editor), Elizabeth Valdezco (Lay-out Editor), Jose Mari Ramos (Art Editor), Camille Portugal (Assistant Art Editor), Joel Tan (Photo Editor), Gerald Renacido (L Case Digest (G.R. No. 56169) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Publication of September–October 1994 issues
- Chi-Rho broadsheet (Vol. 41, No. 14) and Ang Magasing Pampanitikan contained stories, poems and illustrations described by some members of the Miriam College community as “obscene,” “vulgar,” “indecent,” and “sexually explicit.”
- Key contributions included:
- “Kaskas,” a Tagalog fiction by Gerald Gary Renacido, depicting erotic scenes in a go-go bar and subsequent attempted vehicular homicide.
- Ang Magasing Pampanitikan’s “Libog at iba pang tula” edition with foreword “Foreplay” by Jerome Gomez and poems/illustrations by Relly Carpio, Belle Campanario, Belle and others containing erotic metaphors and nudity.
- Disciplinary proceedings at Miriam College
- Letter (Nov. 4, 1994) from the Discipline Committee Chair notifying nine student-journalists of complaints and charging them under the Student Handbook; requiring written answers by Nov. 15.
- Students refused to file answers, asserting DECS regional office jurisdiction under RA 7079; Committee proceeded ex parte and imposed sanctions: expulsions (Briones, Renacido, Ramos), dismissals (Carpio, Gomez), suspensions (Cowper, Hilario, Ligon, Valdezco, Tan), and withholding of graduation privileges (Portugal).
- Judicial petitions and orders
- Students filed for certiorari and prohibition with TRO before RTC Quezon City. Jan. 17, 1995: RTC denied TRO. Feb. 10, 1995: RTC granted preliminary injunction. Feb. 22, 1995: RTC dismissed petition and recalled earlier orders.
- Students elevated case to Court of Appeals. May 19, 1995: CA issued TRO. Sept. 26, 1996: CA declared RTC’s dismissal void and invalidated the suspensions/dismissals.
- Miriam College filed petition for review on certiorari to the Supreme Court (G.R. No. 119027), raising mootness, jurisdiction, and power to discipline issues.
Issues:
- Mootness of the case
- Whether the CA erred in deeming the petition moot and academic.
- Distinction between temporary restraining order and preliminary injunction under the Rules of Court.
- Jurisdiction to entertain the petition for certiorari
- Whether the RTC had jurisdiction despite DECS Order No. 94, s. 1992 implementing RA 7079.
- Applicability of the primary jurisdiction doctrine to administrative vs. judicial bodies.
- Power to suspend or expel student-journalists
- Impact of Section 7, RA 7079 (Campus Journalism Act) prohibiting expulsion/suspension solely for campus journalism duties.
- Constitutional basis for academic freedom and institutional discipline under Article XIV, Sections 3 and 5 of the 1987 Constitution.
- Jurisdiction over complaints
- Whether Miriam College or the DECS regional office had authority to investigate and decide disciplinary cases under RA 7079 and its IRR.
- Due process and impartiality of the Miriam College Discipline Committee and Board.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)