Case Summary (G.R. No. 89317)
Petitioners
Students denied readmission/re-enrollment for Academic Year 1988-1989 after February 1988 mass actions against the school. They sought mandamus relief compelling their re-enrollment.
Respondents
Mabini College invoked the “termination of contract” doctrine (Alcuaz v. PSBA) and alleged academic deficiencies and procedural defaults to justify refusal. The trial court and court of appeals upheld the refusal.
Key Dates
– Trial court order dismissing petition: August 8, 1988
– Denial of reconsideration: February 24, 1989
– Supreme Court en banc acceptance: September 14, 1989
– Decision date: May 20, 1990
Applicable Law
– 1987 Constitution, Art. III, Sec. 4 (freedom of speech and assembly); Art. XIV (education as priority, State supervision)
– Manual of Regulations for Private Schools:
• Para. 107 (right to continuous enrollment barring academic or disciplinary disqualification)
• Para. 137 (fee-liability rules, not enrollment term)
• Para. 145 (due-investigation prerequisite for penalties)
– Batas Pambansa Blg. 232, Sec. 9(2) (student right to continue course except for academic deficiency or disciplinary violation)
– Jurisprudence: Alcuaz v. PSBA (161 SCRA 7), Malabanan v. Ramento (129 SCRA 359), Villar v. TIP (135 SCRA 706), Guzman v. NU (142 SCRA 699).
Background
After leading or joining rallies that temporarily disrupted classes, petitioners were barred from re-enrollment. They filed a mandamus petition in RTC. The RTC dismissed it, citing Alcuaz’ doctrine that a student-school contract ends each semester and schools may refuse subsequent readmission. Reconsideration was denied on grounds of academic freedom and alleged lack of due process.
Procedural History
– RTC dismissal (Aug. 8, 1988); denial of reconsideration (Feb. 24, 1989)
– CA referral (Apr. 10, 1989); certification back to SC (May 22, 1989)
– Transfer to en banc (Aug. 21, 1989); comments and rejoinders exchanged; case submitted
Issues
- Validity of “termination of contract” doctrine as grounds to deny re-enrollment
- Violation of constitutional rights to free speech and assembly
- Requirement of procedural due process in disciplinary measures
- Proper scope of academic freedom vis-à-vis student rights
Reassessment of “Termination of Contract”
Alcuaz misinterpreted Manual para. 137, which regulates fee liability, not enrollment duration. Educational contracts carry public interest and favor continuous enrollment under para. 107 and BP 232 Sec. 9(2). Schools cannot refuse re-enrollment solely because a semester term lapsed.
Constitutional Rights of Students
Under 1987 Const. Art. III Sec. 4, students retain freedom of speech and assembly on campus (Malabanan v. Ramento). Limitations apply only to conduct that materially disrupts classes or invades others’ rights.
Due Process and Discipline
Disciplinary sanctions require: written notice of charges; right to answer with counsel; disclosure of evidence; presentation of defense evidence; and decision by authorized body (Guzman v. NU; Manual para. 145). Penalties must be proportionate (Malabanan).
Academic Freedom Limitations
Institutions may set academic standards but must apply them uniformly and may not use them
Case Syllabus (G.R. No. 89317)
Parties
- Petitioners: Ariel Non, Rex Magana, Alvin Agura, Normandy Occiano, Jorge Dayaon, Lourdes Banares, Bartolome Ibasco, Emmanuel Barba, Sonny Moreno, Giovani Palma, Joselito Villalon, Luis Santos, and Daniel Torres, all students of Mabini Colleges, Inc.
- Respondents: Hon. Sancho Dames II (Presiding Judge, 5th Regional Trial Court, Branch 38, Daet, Camarines Norte) and Mabini Colleges, Inc., represented by its President Romulo Adeva and Chairman of the Board of Trustees Justo Lukban.
Facts of the Case
- Petitioners led or participated in mass student actions and rallies against Mabini Colleges during the first semester of the 1988–1989 academic year.
- In retaliation, school authorities refused to allow petitioners to re-enroll for the second semester.
- The specific subject matter of the protests was not clearly alleged in the pleadings.
- Petitioners allege denial of their constitutional rights to education, free speech, and peaceful assembly, as well as lack of due process.
Procedural History
- Petitioners filed a petition for readmission/enrollment before the trial court.
- Trial court (Aug. 8, 1988) dismissed the petition, citing Alcuaz doctrine that student contracts terminate at semester end.
- Motion for reconsideration denied (Feb. 24, 1989) but judge noted the conflict between student rights and school discipline; upheld Alcuaz.
- Petition for certiorari with preliminary mandatory injunction filed before the Supreme Court.
- Second Division referred the case to the Court of Appeals (Apr. 10, 1989).
- Court of Appeals heard injunctive application; certified case back to the Supreme Court on pure questions of law (May 22, 1989).
- Third Division transferred the case to the Court en banc (Aug. 21, 1989).
- En banc accepted the petition (Sept. 14, 1989), required respondents’ comment (filed Nov. 13, 1989), and obtained petitioners’ reply, counter-comment, and rejoinder.
- Case deemed submitted for decision on pure questions of law.
Issues Presented
- Should the “termination of contract” doctrine from Alcuaz v. PSBA be overturned?
- Can a private school refuse re-enrollment solely because a student’s contract is deemed terminated at the semester’s close?
- Were petitioners denied due process before being refused re-enrollment?
- Did respondent school lawfully invoke academic freedom or legitimate academic deficien