G.R. No. 165569 - University of Santo Tomas vs. Sanchez

Respondent Danes B. Sanchez filed a Complaint for Damages against the University of Santo Tomas (UST), its Board of Directors, Dean Glenda A. Vargas, Assistant Dean Ma. Socorro S. Guanhing, and Registrar Rodolfo N. Clavio.
The case was docketed as Civil Case No. DH-788-02 before Branch 5 of the Regional Trial Court (RTC) of Dinalupihan, Bataan.

Respondent graduated with a Bachelor of Science in Nursing on April 2, 2002; he was included in the graduation list and attended ceremonies.
On April 18, 2002, he paid the required fees to secure his Transcript of Records (ToR) but received only a Certificate of Graduation. Despite submitting class cards as proof of enrollment, UST refused to release his ToR.
The withholding of the ToR prevented him from taking the nursing board examination and deprived him of the opportunity to earn a living.
He prayed that the RTC order UST to release his ToR and award actual, moral, and exemplary damages, attorney’s fees, and costs of suit.

In lieu of an answer, petitioners moved to dismiss, arguing respondent was not a registered student (no enrollment for the last three semesters) and that paragraph 10 of the complaint admitted non-enrollment, thus failing to state a cause of action.
In a Supplement, petitioners alleged respondent had already sought recourse from the Commission on Higher Education (CHED) via a January 21, 2003 letter-complaint, invoking CHED’s primary jurisdiction and rendering the case premature.

The RTC denied the Motion to Dismiss (Order dated April 1, 2003) for requiring an appreciation of evidence at trial; the Motion for Reconsideration was denied (Order dated August 1, 2003).
The Court of Appeals (CA) in CA-G.R. SP No. 79404 affirmed the RTC’s denial (Decision dated July 20, 2004; Resolution dated September 22, 2004) and directed the RTC to proceed with trial.
Petitioners then filed a petition for review on certiorari with the Supreme Court (G.R. No. 165569).

Whether CHED has primary and quasi-judicial jurisdiction over respondent’s demand for the release of his ToR, requiring exhaustion of administrative remedies.
Whether respondent violated the rule against forum shopping by seeking relief from both CHED and the RTC.
Whether the Complaint fails to state a cause of action due to the admitted non-enrollment in the last three semesters.