Title
Regino vs. Pangasi Colleges of Science and Technology
Case
G.R. No. 156109
Decision Date
Nov 18, 2004
A student refused to pay for a school fundraising event due to financial and religious reasons, was barred from exams, and sued for damages. The Supreme Court ruled that exhaustion of administrative remedies was inapplicable, allowing the case to proceed in court.

Case Digest (G.R. No. 164978)
Expanded Legal Reasoning Model

Facts:

  • Background of the School-Student Relationship
    • Enrollment as reciprocal contract: students agree to academic standards and conduct codes; school agrees to provide education and honor fees disclosed upon enrollment.
    • Terms are fixed at enrollment; unilateral mid-term changes or new fees are disallowed.
  • Events Leading to the Complaint
    • Khristine Rea M. Regino enrolled for the second semester of SY 2001-2002 in PCST, taking Logic with Rachelle A. Gamurot and Statistics with Elissa Baladad.
    • PCST’s February 2002 “Rave Party” fund‐raiser required each student to purchase two ₱100 tickets; incentives and penalties (extra test points or denial of final exams) were announced.
    • Regino, financially constrained and on religious grounds objecting to dance parties, refused to pay.
    • On March 14–15, 2002, Gamurot and Baladad barred her from taking final exams, seating her out or ejecting her from class.
    • April 25, 2002: Regino filed a pauper’s Complaint for damages (₱500,000 nominal, ₱500,000 moral, ₱1,000,000 exemplary, ₱250,000 actual, plus costs and fees) against PCST, Gamurot, and Baladad.
    • May 30, 2002: Respondents moved to dismiss for failure to exhaust administrative remedies before CHED.
    • July 12, 2002: RTC (Branch 48, Urdaneta) granted the motion, dismissing for lack of cause of action.
    • November 22, 2002: RTC denied Regino’s motion for reconsideration.
    • Regino petitioned the Supreme Court under Rule 45, challenging the two RTC orders.

Issues:

  • Applicability of Administrative Remedies
    • Does the doctrine of exhaustion of administrative remedies apply to a civil action for damages under the Civil Code’s human relations provisions?
    • Must Regino first seek CHED’s declaration of invalidity or remedy before suing for damages?
  • Sufficiency of the Complaint’s Cause of Action
    • Did the Complaint allege facts sufficient to state causes of action in contract and tort?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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