Case Digest (G.R. No. 97827)
Facts:
University of the Philippines v. Court of Appeals, G.R. No. 97827, February 09, 1993, Supreme Court Third Division, Romero, J., writing for the Court. The petition challenges a regional trial court order denying a motion to dismiss a complaint for damages and the Court of Appeals decision affirming that order.The dispute arose from public academic statements by Professors Zeus Salazar and Jerome Bailen of the University of the Philippines (UP) alleging that the 1971 “Tasaday” discovery was a hoax. At an August 15–17, 1986 conference in Diliman, Bailen presented the “Tasaday Folio” and Salazar traced the Tasadays’ genealogy to T’boli and Manobo groups; both reiterated their views at the 12th International Congress of Anthropological and Ethnological Sciences in Zagreb in July 1988, and their statements received media coverage.
On October 27, 1988, Manuel Elizalde and Tasaday representatives Balayem, Mahayag, Dul and Lobo filed Civil Case No. Q-88-1028 before the Quezon City Regional Trial Court (Branch 89), alleging that Salazar’s and Bailen’s statements defamed and deprived the plaintiffs of peace of mind and sought moral damages, attorney’s fees, and a declaratory judgment recognizing the Tasadays as a distinct ethnic community under Presidential Proclamation No. 995.
On November 24, 1988 UP moved to intervene, asserting institutional academic freedom and seeking to protect its faculty; the court required UP to submit an answer in intervention. Salazar and Bailen moved to dismiss on December 5, 1988; the trial court denied that motion on January 9, 1989. Salazar and Bailen sought relief from the Supreme Court by petition (docketed G.R. No. 87248), which was dismissed by the Court in a minute resolution dated April 3, 1989.
Meanwhile UP’s separate motion to dismiss (filed February 15, 1989) was stricken as improper after UP had filed its answer in intervention; UP then pursued its special defenses (lack of cause of action; lack of jurisdiction over the nature of the action) by a motion for preliminary hearing on those defenses. The trial court denied UP’s attempt to treat those defenses as grounds for dismissal in an Order of May 15, 1989; UP filed a petition for certiorari and prohibition (docketed G.R. No. 88664), which was referred to the Court of Appeals as CA-G.R. SP No. 18074.
The Court of Appeals, by decision of March 12, 1991 (Francisco, J.), dismissed UP’s petition and lifted a previously issued TRO, holding that the sufficiency of the complaint must be determined from the face of the complaint and that defen...(Pro-only)
Issues:
- Does the principle of res judicata bar UP’s petition given prior proceedings (including G.R. No. 87248) contesting denial of an earlier motion to dismiss?
- Did the trial court err in denying UP’s motion to dismiss/denying UP’s invocation of institutional academic freedom and privilege as grounds for dismissal, when such defenses were raised after UP filed an answer in intervention?
- May the trial court grant the plaintiffs’ prayer for a judicial declaration recognizing the Tasadays as a distinct ethnic community under Presidential Proclamation ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)