Case Digest (G.R. No. 159785) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The petitioners—Ariel Non, Rex Magana, Alvin Agura, Normandy Occiano, Jorge Dayaon, Lourdes Banares, Bartolome Ibasco, Emmanuel Barba, Sonny Moreno, Giovani Palma, Joselito Villalon, Luis Santos, and Daniel Torres—were students of Mabini Colleges, Inc. in Daet, Camarines Norte, who led and participated in mass protests against the school during the first semester of the 1988–1989 academic year. When they sought re-enrollment for the next semester, the private respondent refused to admit them, citing alleged academic deficiencies and relying on the “termination of contract” doctrine laid down in Alcuaz v. Philippine School of Business Administration. The petitioners filed a petition for certiorari with a prayer for preliminary mandatory injunction before the 5th Regional Trial Court, Branch 38, presided over by Judge Sancho Dames II, which dismissed their petition on August 8, 1988 and denied reconsideration on February 24, 1989. On appeal, the Court of Appeals, finding only pure Case Digest (G.R. No. 159785) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proceedings
- Petitioners: Thirteen students of Mabini Colleges, Inc., Daet, Camarines Norte, who led or participated in student mass actions in February 1988.
- Respondents: Hon. Sancho Dames II (Presiding Judge, RTC Br. 38, Daet) and Mabini Colleges, Inc. (represented by its president and board chairman).
- Petitioners were barred from re-enrollment for AY 1988–89; they filed a petition for mandamus in the RTC to compel readmission.
- Trial Court Disposition
- RTC (Aug 8, 1988): Dismissed petition, holding itself bound by the “termination of contract” doctrine in Alcuaz v. PSBA (enrollment ends each semester).
- Motion for reconsideration (Feb 24, 1989): Denied, reiterating Alcuaz and ruling petitioners had failed to deny school’s affirmative defenses (due process afforded, disruption of classes, breach of school pledges and enrollment form conditions).
- Supreme Court Proceedings
- Petition for certiorari with preliminary mandatory injunction filed in SC; case referred to CA and then returned to SC en banc.
- SC en banc consolidated pleadings: petition, comment, counter-comment, rejoinder, rejoinder to reply.
- Central controversy: validity of Alcuaz “termination of contract” doctrine and denial of re-enrollment on grounds of protest activity and alleged academic deficiencies.
Issues:
- Doctrinal Issue
- Whether the Alcuaz “termination of contract” doctrine should be overruled, i.e., whether a student–school contract indeed ends at each semester.
- Contractual and Public-Policy Issue
- Whether the student–school relationship is an ordinary contract or one imbued with public interest, affording students a right to complete their course.
- Constitutional and Procedural Issues
- Whether denial of re-enrollment for leading/participating in peaceful protest violated students’ constitutional rights to free speech and assembly.
- Whether petitioners were afforded procedural due process before being denied re-enrollment.
- Whether invoking academic freedom and academic deficiency to bar re-enrollment improperly discriminated against petitioners for exercising fundamental rights.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)