Case Summary (G.R. No. L-56180)
University Investigation and Disciplinary Process
Rev. Welsh conducted a preliminary inquiry by interviewing boarders who witnessed the incident; they confirmed Mateo’s account. Finding probable cause, Rev. Welsh prepared a memorandum to the Board of Discipline and delivered copies to its members. The complaint was read to Juan Ramon on December 14, 1967, in which he admitted the slapping. Separate inquiries sought guidance from college counselors. Notice of the Board meeting (December 19) was posted and the student was personally notified and advised to seek parental or guardian assistance; Juan Ramon nonetheless appeared and admitted the act, sought to leave for Bacolod, and ultimately the Board unanimously resolved to drop him from the rolls. Subsequent administrative reviews by the Dean of Arts and Sciences and by the University President sustained the Board’s decision. Before formal implementation, Juan Ramon requested and was granted an honorable dismissal (clearance issued January 8, 1968), and his tuition for the second semester was refunded by his father.
Trial Court and Appellate Proceedings
The Guanzons filed a civil action for damages in the Court of First Instance of Negros Occidental, alleging that Juan Ramon was expelled without due process and seeking actual, moral, and exemplary damages and attorneys’ fees. The trial court found for the Guanzons and awarded damages. On appeal, the Court of Appeals initially reversed and dismissed the complaint but, upon the Guanzons’ motion for reconsideration and after referral to a special division of five due to a 2–1 split, the appellate court reversed its own reversal and reinstated the trial court judgment. Ateneo petitioned the Supreme Court for review, challenging the appellate division’s conclusion that the Guanzons were denied due process, asserting improper resort to judicial remedies (failure to exhaust administrative remedies), and alleging grave abuse and errors of law and fact.
Issues Presented to the Supreme Court
The petition raised three principal issues: (1) whether the Court of Appeals erred in ruling that the private respondents (the parents) and their son were denied due process in the disciplinary proceedings; (2) whether the filing of the damage suit prematurely curtailed administrative remedies and violated finality/exhaustion principles; and (3) whether the appellate court’s findings were tainted by grave abuse, conflict, or contradiction with the evidence.
Standard of Review on Factual Findings and Administrative Deference
The Supreme Court reiterated the general principle that findings of fact by trial courts and administrative agencies warrant great weight and are ordinarily not disturbed on appeal. However, the Court emphasized well-established exceptions permitting disregard of such findings when they are grounded on speculation or conjecture; when inferences are manifestly mistaken, absurd, or impossible; where there is grave abuse of discretion; where there is misapprehension of facts; where findings go beyond the issues or contradict evidence or admissions; or where administrative findings are unsupported by evidence, tainted by fraud, resulted from irregular procedure, or display palpable error, arbitrariness, or caprice. The Court applied these standards to the records of both the university’s disciplinary proceedings and the courts below.
Analysis of Due Process in the Disciplinary Proceedings
The Supreme Court found that the disciplinary process afforded to Juan Ramon satisfied administrative due process requirements. The record showed that: (a) Juan Ramon was informed of the charges when the complainant’s letter was read to him; (b) he admitted the slapping during the initial inquiry; (c) the investigating officer interviewed independent witnesses who corroborated elements of Mateo’s account; (d) the Board of Discipline was composed of impartial, competent faculty members; (e) notice of the formal Board meeting was given and the student was personally informed and told he could seek assistance from parents or counselors; and (f) the Board’s decision was reviewed by higher university authorities in accordance with institutional procedures. The Court observed that Juan Ramon, an 18-year-old college student, was mature and aware of the gravity of the charge (he even asked whether he would be expelled) and that his failure to notify his parents was a personal choice that did not constitute denial of due process by the university. The Court also noted that the evidentiary record supported the finding of “unbecoming conduct” — including the use of offensive language, the public nature of the incident, and contemporaneous witness statements — and that the university’s published rules identified such conduct as ground for disciplinary action.
Consideration of Administrative Finality and Exhaustion of Remedies
Ateneo argued that the Guanzons’ civil suit was premature because an administrative appeal from the Ministry of Education decision to the President of the Philippines was pending. The Supreme Court rejected this contention, distinguishing between administrative processes that are prerequisites to judicial relief and purely legal claims cognizable by civil courts. The Court characterized the Guanzons’ action as a civil claim for damages under the Civil Code — a legal cause of action properly within the jurisdiction of the courts — and held there was no requirement to await administrative review (citing precedents such as Gonzales v. Hechanova; Tapales v. University of the Philippines; and others). Thus, the filing of a civil action for damages did not violate exhaustion doctrines in the circumstances.
Entitlement
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Procedural History
- Letter-complaint dated December 13, 1967 by Carmelita Mateo (waitress at Cervini Hall cafeteria, Ateneo de Manila) alleging that Juan Ramon Guanzon slapped her on December 12, 1967 at about 5:15 p.m.
- Ateneo de Manila University conducted an internal disciplinary investigation and, on the basis of its findings, dismissed (dropped from the rolls) Juan Ramon Guanzon.
- Parents (Spouses Romeo G. Guanzon and Teresita Regalado) filed a complaint for damages in the Court of First Instance of Negros Occidental at Bacolod City, alleging expulsion without fair trial (violation of due process) and claiming actual, moral, and exemplary damages and attorney’s fees.
- The university denied material allegations, justified dismissal under its disciplinary regulations, and asserted its authority to drop students undesirable for maintaining institutional integrity and discipline.
- After trial, the lower court found for the Guanzons and awarded P92.00 actual damages, P50,000.00 moral damages, P5,000.00 attorney’s fees, and costs.
- The university appealed to the Court of Appeals; the appellate court initially reversed and dismissed the complaint.
- Upon motion for reconsideration by the Guanzons, the Court of Appeals, in a special division of five (due to lack of unanimity in the regular division, 2–1), reversed its earlier ruling and reinstated the trial court’s decision.
- Ateneo petitioned the Supreme Court for review, raising three assigned errors to reverse the Court of Appeals’ division of five resolution.
Central Issues Presented to the Supreme Court
- Whether the Court of Appeals’ division of five gravely erred in ruling that private respondents (the parents) were not accorded due process in the disciplinary case against their son, Juan Ramon Guanzon.
- Whether the Court of Appeals erred in ruling that the resort by private respondents to judicial remedy did not violate the rule on finality of administrative action or the doctrine of exhaustion of administrative remedies, given a pending appeal from the Minister of Education to the President of the Philippines.
- Whether the findings and conclusions of the Court of Appeals’ division of five were tainted with grave abuse of discretion, conflicting, or contrary to the evidence.
Factual Background (Details of the Incident)
- On December 12, 1967, at approximately 5:15 p.m. in the Cervini Hall cafeteria, Juan Ramon Guanzon allegedly sought "siopao" and was told by waitress Carmelita Mateo that it had yet to be heated and to wait.
- According to Mateo’s December 13, 1967 letter-complaint, Guanzon began mumbling bad words directed at her, in the hearing presence of other boarders; she asked him to stop cursing and he responded it was none of her business.
- Mateo attempted to give back his money; he refused, grew angrier, cursed again, threatened to strike her with his fist, and then struck her in the left temple.
- Mateo sought to avoid further blows and obtained a bottle to dodge him; fellow boarders restrained Guanzon and Dr. Bella and Leyes coaxed him to stop; Fr. Campbell arrived but the incident had been hidden from him by the boarders.
- Mateo left to the kitchen crying because she was hurt and could not report the incident to Fr. Campbell personally at the time.
- Testimony and investigative interviews included statements from companions/friends present: Eric Tagle, Danny Go, Roberto Beriber, and Jose Reyes; they confirmed aspects of the incident and were interviewed in the preliminary inquiry.
- A friend, Roberto Beriber, told Rev. Welsh that Guanzon made threatening gestures prompting Mateo to pick up and throw a cardboard box top; Mateo also shouted at Guanzon and attempted to hit him.
- Evidence showed the altercation began with Juan Ramon’s utterance of the Ilongo phrase "bilat ni bay," translated in the record as "sex organ of a woman."
Disciplinary Proceedings Conducted by the University (Steps Taken)
- Rev. William Welsh, S.J., in his capacity as Chairman of the Board of Discipline, conducted a preliminary inquiry upon receipt of the letter-complaint and interviewed the companions/friends of Juan Ramon who confirmed the incident (Exhs. 5, 6, 7 and 9).
- Finding probable cause, Rev. Welsh prepared a memorandum to the Board of Discipline dated December 16, 1967 (Exh. 8) and delivered copies to members: Fr. Francisco Perez, Dr. Amada Capawan, Mr. Piccio, and Dr. Reyes.
- On December 14, 1967, the letter-complaint was read to Juan Ramon and he admitted the truth of the charge (trial stenographic notes referenced).
- Rev. Welsh sent letters dated December 18, 1967 to Rev. Antonio Cuna (Student Counselor) and Rev. James Culligan (Director of Guidance) seeking guidance/information for the Board’s action (Exhs. 10-11).
- Notice of the Board meeting set for December 19, 1967 was posted on the College and dormitory bulletin boards; the Secretary of the Dean of Discipline personally notified Juan Ramon and told him to seek help from guardians, parents, friends, and counselors (tsn references).
- Juan Ramon appeared before the Board of Discipline, admitted the slapping, and asked to be excused to catch the boat to Bacolod City for Christmas vacation.
- The Board of Discipline’s decision to drop Juan Ramon from the rolls was unanimous (Exh. 12); the Dean of Arts and Sciences reviewed and found no ground to reverse (Exh. 13); the President of the University sustained the Board’s decision (Exh. 21-A, p. 6).
- A motion for reconsideration filed by the President of the Student Council on behalf of Juan Ramon (Exh. 15) was denied by the University President.
- Before implementation of the Board’s decision, Juan Ramon voluntarily applied for and received an honorable dismissal; he obtained his clearance on January 8, 1968 (Exh. 3, tsn).
- Romeo Guanzon (father) arranged for a full refund of tuition fees for the entire second semester of 1967–68; Juan Ramon was admitted to De La Salle College of Bacolod and later transferred to another Jesuit school.
Trial Court Findings and Relief
- The Court of First Instance of Negros Occidental at Bacolod City found for the plaintiffs (Spouses Guanzon) and ordered the university to pay:
- P92.00 as actual damages;
- P50,000.00 as moral damages;
- P5,000.00 as attorney’s fees;
- and the costs of suit.