Case Summary (G.R. No. 174996)
Factual Background
St. Francis School of General Trias, Cavite, Inc. was founded on July 9, 1973, as a non-stock, non-profit educational institution, with its initial incorporators including Custodio, Mojica, Pascual, and two other individuals. By 1988, a Memorandum of Agreement (MOA) was executed between the school and De La Salle Greenhills (DLSG), which allowed DLSG to supervise the school’s academic affairs. Subsequent to this, several brothers from DLSG were elected to key positions within the school’s Board of Trustees. Custodio challenged the validity of these elections, claiming that proper procedures had not been followed for the admission and election of DLSG’s representatives.
Legal Proceedings and Removal of Custodio
Custodio’s contestation led to an escalating series of legal disputes beginning in 2002, notably with a complaint questioning the legality of the Board of Trustees' composition. Following her objections to a proposed MOA granting DLSG broader powers, Custodio was removed from her position as Curriculum Administrator via resolutions adopted by the Board of Trustees citing a "willful breach of trust." She subsequently filed a complaint in the Regional Trial Court (RTC) seeking injunctive relief against this removal.
Status Quo and Court Orders
On multiple occasions, the RTC issued orders pertinent to the continue operation of the school and addressed the conflicts arising from Custodio's removal. Notably, an order dated August 21, 2003 reinstated Custodio's powers, dictating that she could act as the school director and curriculum administrator until a further resolution of the conflict was reached.
Court of Appeals Ruling
Dissatisfied with the RTC rulings, the petitioners appealed to the Court of Appeals. They claimed that they were denied due process due to the manner in which these orders had been issued and that the status quo order lacked the necessary procedural safeguards, such as a required bond prior to its issuance. The Court of Appeals upheld the RTC’s orders, prompting petitioners to file a petition for review with the Supreme Court.
Supreme Court's Analysis
The Supreme Court analyzed the claims of grave abuse of discretion by the RTC in issuing the August 5, 2003, and October 8, 2003 orders, determining that while the petitioners were not deprived of due process, the August 21, 2003 Status Quo Order had been improperly issued. The Court emphasized tha
...continue readingCase Syllabus (G.R. No. 174996)
Overview of the Case
- The case revolves around a petition for review under Rule 45 of the 1997 Rules of Civil Procedure, targeting the Decision dated September 16, 2005, and the Resolution dated October 9, 2006, from the Court of Appeals in CA-G.R. SP No. 79791.
- The petitioners include Bro. Bernard Oca, Bro. Dennis Magbanua, Mrs. Cirila Mojica, Mrs. Josefina Pascual, and St. Francis School of General Trias, Cavite, Inc.
- The respondent is Laurita Custodio, who contested her removal from the corporation and board of trustees of the school.
Factual Background
- St. Francis School of General Trias, Cavite, Inc. (the School) was established on July 9, 1973, as a non-stock and non-profit educational institution with help from the La Salle Brothers.
- The original incorporators included Laurita Custodio, Cirila Mojica, Josefina Pascual, Rev. Msgr. Feliz Perez, and Bro. Vernon Poore.
- A Memorandum of Agreement (MOA) executed on September 8, 1988, allowed De La Salle Greenhills (DLSG) to supervise the School’s academic affairs.
- Over time, Bro. Victor Franco, Bro. Bernard Oca, and Bro. Dennis Magbanua became involved as supervisors and members of the Board of Trustees.
- Custodio questioned the legality of the DLSG Brothers' membership and their election as officers, claiming no formal admission as members or election took place.
Legal Proceedings Initiated by Custodio
- Following disagreements regardi