Case Summary (G.R. No. L-56180)
University Disciplinary Proceedings
Father Welsh, Chairman of the Board of Discipline, conducted a preliminary inquiry by interviewing eyewitnesses. A memorandum finding probable cause was sent to board members. On December 14, Juan Ramon was informed of the charge and admitted the slapping. Notices of a December 19 hearing were posted and personally delivered; Juan Ramon appeared, again admitted the offense, then left for vacation. The Board unanimously resolved to drop him from the rolls; this decision was affirmed successively by the Dean of Arts & Sciences, the University President, and denied reconsideration. Before enforcement, Juan Ramon applied for—and received—an honorable dismissal on January 8, 1968. His second semester tuition was fully refunded by his father.
Lower Court Proceedings
The Guanzons sued the university in the Court of First Instance of Negros Occidental, alleging expulsion without due process and claiming P92 actual damages, P50,000 moral damages, P5,000 attorney’s fees, and costs. The trial court found for the parents and granted their claim.
Appellate Court Proceedings
On appeal, the Court of Appeals initially reversed and dismissed the complaint. Upon motion for reconsideration, a special five-member division, split 2–1, reinstated the lower court’s award, holding that due process had not been observed and that the parents’ judicial remedy did not violate finality or exhaustion rules.
Issues for Review
- Whether the Division of Five erred in finding a due process violation in the disciplinary case.
- Whether resort to judicial remedy was premature or violated exhaustion of administrative remedies.
- Whether the appellate resolution’s findings evince grave abuse of discretion or are unsupported by evidence.
Standard on Review of Factual Findings
While trial and administrative fact-findings are generally accorded great weight, they may be disregarded when they rest on conjecture, are impossible, show grave abuse of discretion, misapprehend facts, contravene evidence, are unsupported by evidence, vitiated by fraud or irregular procedure, or manifest capriciousness.
Due Process in Disciplinary Actions
The University’s hearings were fair, open, exhaustive, and adequate: the student was informed of charges, confronted with witnesses, given opportunity to present his account, and decisions were reviewed at three hierarchical levels. His voluntary honorable dismissal does not negate the fact that administrative due process was fully observed. The parents’ absence at the proceedings does not constitute a violation since the student, an adult and mature first‐year college student, was properly notified and advised to seek guardians’ assistance.
Exhaustion of Administrative Remedies
The action for damages under Civil Code provisions is a civil remedy independent of pending administrative appea
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Facts of the Incident
- On December 12, 1967 at about 5:15 p.m., in the Cervini Hall cafeteria of Ateneo de Manila University, first‐year boarder Juan Ramon Guanzon asked cafeteria waitress Carmelita Mateo for “siopao.”
- Mateo replied that the siopao needed heating and asked him to wait; Guanzon responded by mumbling curses in her hearing presence.
- When Mateo reproached him, Guanzon told her it was none of her business, grew impatient, and refused the return of his money.
- He then escalated to threats of physical violence and struck Mateo on the left temple before bystanders restrained him.
- Mateo retreated to the kitchen in tears; Fr. Campbell arrived too late to intervene.
Administrative Proceedings
- December 13, 1967: Mateo filed a letter‐complaint with Rev. William Welsh, S.J., Chairman of the Board of Discipline.
- Fr. Welsh conducted a preliminary inquiry, interviewing four of Guanzon’s companions who confirmed the slapping incident.
- December 14, 1967: Guanzon was formally informed of the complaint, read the letter, and admitted the facts.
- December 16–18, 1967: Fr. Welsh circulated a memorandum to Board members and sought guidance from student counselors and the Director of Guidance.
- December 19, 1967: Notice of the Board’s meeting was posted and personally served on Guanzon, who appeared, admitted the slapping, and asked to be excused to catch his boat home.
- The Board of Discipline, composed of five senior faculty members, voted unanimously to drop Guanzon from the rolls; the Dean and University President affirmed the decision.
- Before implementation, Guanzon applied for and received an honorable dismissal on January 8, 1968, obtained a full refund of second‐semester tuition, and enrolled elsewhere.
Trial Court Proceedings
- Guanzon’s parents filed a complaint for damages in the Court of First Instance of Negros Occidental, alleging lack of due process in their son’s expulsion and claiming actual, moral, and exemplary damages plus attorney’s fees.
- The university answered, denying due‐process violation and asserting its disciplinary prerogative to maintain institutional integrity.
- The trial court ruled for the Guanzons, awarding ₱9