Case Digest (G.R. No. 162299) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Saint Louis University, Inc. v. Olairez, G.R. Nos. 162299 & 174758, the petitioners include Saint Louis University, Inc. (SLU), Dean Elizabeth Fe-Dacanay, Atty. Arnulfo Soriano, Dr. Roberto Legaspi, Dr. Anastacio Aquino, Lourdes Jacinto, Dr. John Anthony Domantay, and Nora Ponoc. The respondents, Baby Nellie M. Olairez, Shieryl A. Rebucal, Jenny Riza A. Banta, and Brando B. Badecao (collectively the Olairez group), were fourth-year medical students at SLU as of March 2002 in Baguio City. The students filed a complaint before the Regional Trial Court (RTC), Civil Case No. 5191-R, seeking to enjoin SLU from enforcing a revised Comprehensive Oral and Written Examination (COWE) requirement that would delay their graduation. On April 9, 2002, the RTC issued a Preliminary Injunction preventing SLU from implementing the Revised COWE, and on July 16, 2003, rendered a final decision declaring the Olairez group as duly graduated, ordering SLU officials to release their clearances, cert Case Digest (G.R. No. 162299) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the dispute
- Saint Louis University, Inc. (SLU)
- A CHED-accredited medical college in Baguio City.
- Revised its Comprehensive Oral and Written Examination (COWE) by adding “Orals 1 and 2” and extended clerkship months.
- Student plaintiffs (“Olairez group”)
- Baby Nellie M. Olairez, Shieryl A. Rebucal, Jenny Riza A. Banta, Brando B. Badecao; fourth-year medicine students, Batch 2002.
- Filed a Complaint for Mandatory Injunction (Civil Case No. 5191-R, RTC Baguio) on March 18, 2002, challenging the Revised COWE as contrary to the SLU Student Handbook and an arbitrary graduation delay.
- Interim relief and amended complaint
- April 9, 2002: RTC grants preliminary injunction enjoining enforcement of Revised COWE.
- Fourth Amended Complaint prayed for issuance of clearances, certificates, diploma, registration in SLU Registry, lifting of pressure on APMC and BGH internship, and damages.
- Trial court proceedings
- RTC Decision (July 16, 2003)
- Declared plaintiffs as graduates of SLU College of Medicine, having met CHED requirements and attended graduation rites.
- Ordered SLU to issue clearances, diplomas, transcripts, include them in ROG; cease exerting pressure on APMC/BGH; declared Revised COWE moot; dismissed damage claims.
- Post-judgment events
- July 17, 2003: Plaintiffs attempt compliance; file “Very Urgent Motion to Cite Defendants in Contempt.”
- July 18, 2003: RTC issues order to show cause for contempt; resets hearing to July 22 for technical defect compliance; nonetheless issues writ of execution.
- July 19, 2003: Writ served on SLU; July 23, 2003: RTC finds Dean Dacanay and officers guilty of indirect contempt; fines imposed.
- Appellate and special civil actions
- SLU’s Rule 65 certiorari petition (CA SP 78127)
- Questioned RTC’s orders of July 18 (show‐cause), June 6 (compliance), July 18 writ issuance and execution order.
- CA resolutions (Nov 18, 2003; Feb 10, 2004) dismissed petition for failure to file motion for reconsideration.
- Olairez group’s appeal from contempt order (CA G.R. CR 27861)
- CA Decision (April 7, 2006) reversed RTC contempt order for lack of written charge and opportunity to be heard.
- CA Resolution (Sept 11, 2006) denied motion for reconsideration.
- Consolidation before the Supreme Court
- G.R. No. 162299: SLU’s Rule 45 petition on CA’s certiorari dismissals.
- G.R. No. 174758: Olairez group’s Rule 45 petition on CA’s contempt reversal.
- April 16, 2007 Resolution: cases consolidated.
Issues:
- G.R. No. 162299
- Whether the CA erred in dismissing SLU’s certiorari petition on the ground that pendency of an appeal precludes certiorari.
- Whether the CA erred in dismissing for failure to file a motion for reconsideration of RTC orders.
- G.R. No. 174758
- Whether the CA gravely abused discretion in finding a three-day notice rule violation in contempt proceedings.
- Whether the CA erred in finding due process denial by not affording respondents reasonable opportunity to explain conduct.
- Whether the CA erred in ruling that the initiatory pleading could not be treated as a motion for execution.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)