Case Digest (G.R. No. L-25024)
Facts:
Teodoro C. Santiago, Jr., Minor, represented by his mother, Mrs. Angelita C. Santiago, Petitioner-Appellant, vs. Miss Juanita Bautista, Rosalinda Alpas, Rebecca Matugas, Milkita Inamac, Romeo Agustin, Aida Camino, Luna Sarmago, Aurora Lorena, Soledad Francisco and Mr. Flor Marcelo, Respondents-Appellees, G.R. No. L-25024, March 30, 1970, the Supreme Court En Banc, Barredo, J., writing for the Court.The petitioner, a sixth-grade pupil at Sero Elementary School in Cotabato City, filed Civil Case No. 2012 in the Court of First Instance of Cotabato seeking certiorari, injunction and damages to annul the committee’s ranking of honor students for the 1964–1965 school year that placed him third. The challenged respondents included the school principal (Mrs. Aurora Lorena) as committee chair, several Grade VI teachers (including Juanita Bautista, Rosalinda Alpas, Rebecca Matugas, Milkita Inamac, Romeo Agustin, Aida Camino, Luna Sarmago), and supervisory officials identified in the complaint.
The complaint alleged petitioner’s long record as an honor student, alleged irregularities in the committee’s constitution (that teachers of Grade V were excluded contrary to the Service Manual), improper tutoring and favoritism (notably by Mrs. Alpas toward another pupil), alterations and unexplained increases in some pupils’ grades, unauthorized district examinations affecting ratings, erasures in petitioner’s earlier certificate, failure of school authorities to give effective relief despite petitioner’s appeals, and prayed among other reliefs for annulment of the ranking and a temporary injunction against proclaiming the honor list at graduation (scheduled May 21, 1965) and for damages of P10,000.
The lower court denied the requested temporary restraining order and preliminary injunction on May 20, 1965 because graduation was imminent. Respondents were ordered to answer but instead filed a motion to dismiss on May 24, 1965 asserting impropriety of certiorari, lack of jurisdictional basis, and that the matter had become academic. On June 4, 1965 the Court of First Instance granted the motion and dismissed the petition, holding (1) the petition failed to comply with the second paragraph of Rule 65, Sec. 1 (no certified copy of the judgment/order and relevant pleadings attached), (2) petitioner failed to exhaust administrative remedies, and (3) th...(Subscriber-Only)
Issues:
- Is the committee on the rating of students for honor a "tribunal, board, or officer exercising judicial functions" within the meaning of Rule 65, Sec. 1, so that certiorari lies?
- Did the petition comply with the requirements of Rule 65, Sec. 1 (specifically attaching a certified true copy of the judgment or order complained of and relevant pleadings and documents)?
- Had petitioner exhausted administrative remedies such that certiorari was proper?
- Do the allegations of irregularity and errors in ratings rise to the level of gra...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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