Case Summary (G.R. No. 193584)
Petitioners’ Allegations
- National University refused to re-enroll petitioners because they participated in peaceful mass actions on campus, thereby penalizing their exercise of constitutional freedoms.
- This refusal continued the hostile attitude condemned in San Juan (1983), demonstrating contempt for due process.
- Petitioners effectively faced expulsion without cause, notice, or opportunity to defend, in violation of settled due-process requirements (citing Berina).
Respondents’ Contentions
- Enrollment failures resulted from petitioners’ own tardiness or academic deficiencies, not from exercise of constitutional rights.
- Urbiztondo sought re-enrollment only after the period closed (July 5, 1984).
- Guzman’s poor academic record stemmed from leading class boycotts; he faced pending criminal and civil cases for property destruction.
- Ramacula likewise led disruptive activities without permit.
- Petitioners lacked good scholastic standing.
- Petitioners’ hostility toward the University forfeited any privilege to enroll; post-semester re-enrollment is not required.
Preliminary Court Resolutions
October 2, 1984: The Court noted respondents’ comment, required petitioners’ reply, and issued a mandatory injunction directing respondents to admit petitioners for the coming semester without prejudice to disciplinary proceedings. Guzman, despite pending criminal charges, was allowed to resume studies.
November 23, 1984: The Court gave due course to the petition, treated respondents’ comment as answer, and required memoranda.
Pleadings and Procedural Observations
– Petitioners denied late enrollment and insisted their applications were persistently refused.
– They argued the injunction did not limit their constitutional freedoms and that respondents repeatedly denied permits for lawful campus activities.
– Neither respondents’ comment nor memorandum showed any formal disciplinary proceedings or duly published rules authorizing refusal of re-enrollment for alleged misconduct or scholastic deficiency.
Legal Analysis on University Discipline and Due Process
- Power of Private Institutions: Universities may adopt and enforce rules “expedient for its government,” including student discipline (Pratt v. Wheaton College).
- Statutory Student Rights: Under the Education Act of 1982, students may freely choose and continue their course except for academic deficiency or disciplinary violations.
- Manual of Regulations: No penalty may be imposed “except after due investigation” under duly promulgated rules. Private schools must specify disciplinary rules and sanctions in writing and notify students.
- Due-Process Standards in Student Discipline:
a. Written notice of nature and cause of accusations.
b. Op
Case Syllabus (G.R. No. 193584)
Facts
- Petitioners Diosdado Guzman, Ulysses Urbiztondo and Ariel Ramacula were students of respondent National University, Inc.
- The University refused to allow petitioners to enroll for the first semester of the 1984–1985 school year.
- Petitioners filed a petition for “extraordinary legal and equitable remedies with prayer for preliminary mandatory injunction” on August 7, 1984 (G.R. No. 68288).
Petitioners’ Allegations
- Respondent’s stated ground for refusal was petitioners’ participation in peaceful mass actions within University premises.
- This refusal was a continuation of a “cavalier if not hostile attitude” toward students’ constitutional rights, previously addressed in Rockie C. San Juan vs. National University (G.R. No. 65443, 1983).
- Petitioners claimed they faced expulsion without being informed of any cause and without being afforded an opportunity to defend themselves, invoking Berina v. Philippine Maritime Institute (117 SCRA 581, 1983).
Respondents’ Contentions
- Petitioners’ failure to enroll was due to their own fault, not the exercise of constitutional or human rights.
- Urbiztondo purportedly sought re-enrollment only on July 5, 1984, after the enrollment period closed.
- Guzman allegedly had poor academic performance due to leading class boycotts; his father had threatened to recall him to the province if he did not “reform.”
- Guzman faced a pending criminal case for malicious mischief (MTC Manila Crim. Case No. 066446) and a civil suit for damages (RTC Manila Civ. Case No. 8320483) arising from alleged destruction of University property.
- Ramacula likewise was said to have led unpermitted activities that disrupted classes, contrary to a November 23, 1983 resolution of this Court (G.R. No. 65443) and University regulations.
- Petitioners were characterized as not of good scholastic standing and as having forfeited any privilege to re-enroll.
- Respondents argued that, semestrally enrolled, petitioners cou