Case Digest (G.R. No. 132344)
Facts:
University of the East v. Romeo A. Jader, G.R. No. 132344, February 17, 2000, First Division, Ynares‑Santiago, J., writing for the Court.Respondent Romeo A. Jader was a fourth‑year law student at the University of the East (UE) enrolled from 1984 to 1988. In the first semester of his final year (1987‑1988) he failed to take the regular final examination in Practice Court I and was given an incomplete grade. On February 1, 1988 he filed for removal of the incomplete grade; he took the removal examination on March 28, 1988, and on May 30, 1988 the professor, Carlos Ortega, submitted a failing grade of five (5).
Meanwhile, the College of Law faculty and the dean deliberated on candidates for graduation and prepared a tentative list that included Jader’s name with annotations noting his incomplete in Practice Court I. The tentative list and invitation for the 35th investiture and commencement ceremonies (scheduled April 16, 1988) bore a caveat that the list was tentative and that degrees would be conferred on those who “satisfactorily complete requirements.” During the ceremony Jader went on stage, received the hood and had his tassel turned; Dean Celedonio Tiongson handed him a rolled white sheet symbolizing the diploma.
Believing he would graduate, Jader prepared for the bar: he took a leave of absence without pay (April 20–September 30, 1988) and enrolled in pre‑bar review at Far Eastern University. After learning of his deficiency he dropped the review and was unable to take the 1988 bar examinations.
Jader sued UE for damages alleging negligent misrepresentation/misleading withholding of information which caused moral shock, mental anguish, anxiety, damaged reputation, sleepless nights, and denied opportunity to take the bar; he prayed for moral and exemplary damages, unrealized income, attorney’s fees, and costs. UE denied liability and counterclaimed, arguing it never led Jader to believe he had completed requirements because his name appeared only on a tentative list.
The Regional Trial Court (Manila, Branch IX) found for Jader and ordered UE to pay P35,470.00 with legal interest from filing, P5,000 attorneys’ fees, and costs; UE’s counterclaim...(Subscriber-Only)
Issues:
- May an educational institution be held liable for damages for misleading a student into believing that he has satisfied all requirements for graduation?
- Was the award of moral damages to the student proper under the ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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