Case Summary (G.R. No. 85839)
Events Leading to Disciplinary Action
In April 1988, the USC announced a 9% increase in tuition and fees, citing compliance with R.A. No. 6640, which mandated increases in salaries for certain university staff. Student leaders Licup, Tabasa, and Cairo protested the increase, conducting research they claimed supported their assertion that salaries could be raised without a fee hike. When negotiations failed, a mass protest occurred that included blocking university access points and displaying demands via posters.
Initial Administrative Response
Following the protests, Fr. Gregorio Favia issued a memorandum restricting protest activities within classrooms. Subsequently, Fr. Salazar initiated administrative actions against the protest leaders, instituted a Formal Inquiry Committee to investigate potential violation of university regulations, and ultimately led to a finding that the petitioners had committed offenses worthy of disciplinary action.
Investigation and Findings
The Formal Inquiry Committee, composed of faculty members, investigated the actions of the petitioners, culminating in a report that found them guilty of rule violations. On November 16, 1988, they were notified that they faced non-readmission for the second semester as punishment for their actions, a decision later upheld unanimously by the Disciplinary Board.
Appeal Process
The petitioners appealed the decision to the Department of Education, Culture and Sports (DECS), which stated it had no jurisdiction over the matter and suggested seeking reconsideration directly from the USC President. In the interim, the petitioners were barred from entering university premises by security forces, prompting them to seek a legal remedy through a petition for certiorari.
Allegations of Due Process Violations
In their petition, Licup, Tabasa, and Cairo claimed they suffered irreparable injuries, asserted that their demonstrations were peaceful, contended that their due process rights were violated during the investigation, and argued that the resulting disciplinary measure was excessive in relation to their actions. They specifically challenged the authority and impartiality of the Formal Inquiry Committee.
Respondent's Defense
The respondents defended the tuition increase as necessary and asserted that the student protests breached university rules, leading to disruptions. They maintained that the disciplinary proceedings were fair and conducted properly, with emphasis on the petitioners being present and able to introduce evidence with legal representation.
Court's Evaluation of the Case
Upon review, the Court found no merit in the petitioners' claims. It determined that their actions du
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Case Background
- The University of San Carlos (USC) announced a 9% increase in tuition and other fees effective for the first semester of the academic year 1988-1989, citing compliance with R.A. No. 6640 which mandated salary increases for teachers and non-academic personnel earning below P100.00 daily.
- Student leaders Emmanuel S. Licup, Noel F. Tabasa, and Joel Marc Cairo protested against this tuition hike, arguing that USC could fund salary increases without raising tuition fees.
- The Supreme Student Government, led by the petitioners, sought dialogue with USC officials to reconsider the tuition increase but were met with refusal, prompting mass protests, including demonstrations and blockades at university entrances.
Administrative Actions Taken
- Fr. Gregorio Favia, USC's vice president for academic affairs, prohibited student leaders from campaigning against the tuition increase inside classrooms.
- President Fr. Roderick Salazar, Jr. initiated administrative procedures against the petitioners for alleged violations of university rules.
- A Formal Inquiry Committee was created comprising notable faculty members to investigate the matter. The petitioners challenged the committee's impartiality and its authority to charge them based on a university handbook they claimed was issued without student consultation.
Findings and Disciplinary Actions
- On November 15, 1988, the Inquiry Committee