Case Summary (G.R. No. 156109)
Key Dates
- February 2002: Fundraising campaign announced.
- March 14–15, 2002: Regino denied her Logic and Statistics final exams.
- April 25, 2002: Complaint for damages filed in RTC Urdaneta (Civil Case No. U-7541).
- May 30, 2002: Respondents’ Motion to Dismiss for failure to exhaust administrative remedies.
- July 12, 2002: RTC Order dismissing complaint for lack of cause of action.
- November 22, 2002: RTC denial of reconsideration.
- November 18, 2004: Supreme Court decision.
Applicable Law
- 1987 Philippine Constitution, Article XIV, Sections 5(1) and 5(3) on the State’s duty to protect and promote quality education and students’ right to fair academic requirements.
- Republic Act No. 7722 (Higher Education Act of 2001), defining CHED’s powers (which do not include awarding damages).
- Education Act of 1982 (BP 232), Section 54 and Section 9(2) on CHED supervision and students’ rights.
- Civil Code Articles 19 (good faith), 21 (tortious compensation for conduct contrary to morals/public policy), and 26 (protection of dignity and privacy).
Facts of the Case
Regino enrolled for her second semester in SY 2001–2002 to take Logic (Gamurot) and Statistics (Baladad). PCST imposed a mandatory ₱200 dance-party fee mid-term, threatening non-payers with disqualification from final examinations and grade incentives for paying students. Regino, unable to pay and barred by her faith from attending dances, was prohibited from taking her exams and suffered academic delay and emotional distress. She paid all standard tuition but refused the ticket purchase on conscientious and financial grounds.
Procedural History
Regino sued PCST and the two instructors for nominal, moral, exemplary, actual damages, attorney’s fees, and costs. Respondents moved to dismiss for lack of cause of action and for failure to exhaust administrative remedies before CHED. The RTC granted the motion, dismissing the complaint for lack of cause of action and deeming CHED the proper forum. The RTC denied reconsideration. Regino filed a Rule 45 petition challenging the dismissal.
Issues
- Whether the doctrine of exhaustion of administrative remedies applies to a civil action for damages under the Civil Code’s human-relations provisions.
- Whether prior CHED invalidation of a school policy is a prerequisite to a court-based damage action.
- Whether the complaint stated sufficient causes of action.
Ruling on Exhaustion of Administrative Remedies
- The exhaustion doctrine exists to allow administrative bodies to correct their own errors, but it applies only where the agency has competence over the remedy sought.
- CHED lacks authority to award damages; it regulates academic standards and institutions but cannot redress private damage claims.
- Regino sought purely judicial relief (damages) for tortious and contractual violations, not administrative or policy reversal.
- Exception to exhaustion applies when an issue is purely legal and within court jurisdiction; interpreting Civil Code provisions is a judicial function.
Ruling on Sufficiency of Cause of Action
- A complaint states a cause of action if its allegations, assumed true, entitle the plaintiff to relief.
- Regino’s factual averments—forced ticket purchase, threats, coercion, refusal to sit for exams, and resulting academic and emotional injury—admit two grounds:
• Breach of the reciprocal school-student contract by unilaterally imposing a new fee mid-term, thereby depriving her of contractual benefits (examination and course completion).
• Tort liability under Civil Code Articles 19, 21, and 26 for willful acts contrary to morals/public policy, inflicting humiliation and mental suffering.
Contractual Obligations of Educational Institutions
- The school-student relationship is a bilateral contract: the school provides education under stated standards and fees; the student complies with academic rules and timely payments.
- Terms are fixed at enrollment; mid-term imposition of new fees inconsistent with the enrollment contract is invalid.
- Constitutional and statutory provisions protect students’ rights to continued study and graduation absent academic or disciplinary deficiencies.
Liability for Tort
- Even in contr
Case Syllabus (G.R. No. 156109)
Procedural Antecedents
- Petition for Review under Rule 45 filed in the Supreme Court, challenging two RTC orders in Civil Case No. U-7541, Branch 48, Urdaneta City, Pangasinan
- July 12, 2002 Order of the RTC granted respondents’ Motion to Dismiss “for lack of cause of action”
- November 22, 2002 Order of the RTC denied petitioner’s Motion for Reconsideration
- Petition raises pure questions of law regarding administrative exhaustion, CHED jurisdiction, and sufficiency of the complaint
Factual Background
- Petitioner, a first-year computer science student at PCST, came from a poor family and relied on relatives for support
- During the second semester of SY 2001-2002, PCST held a fund-raising “Rave Party and Dance Revolution,” requiring each student to purchase two tickets at ₱100 each
- The school allegedly granted extra test points to students who bought tickets and barred non-payers from taking final examinations
- Due to financial constraints and religious convictions, petitioner refused to buy tickets; on March 14–15, 2002, her instructors (Gamurot and Baladad) allegedly prevented her from taking final exams in Logic and Statistics
- Petitioner then filed, as a pauper litigant on April 25, 2002, a Complaint for damages against PCST, Gamurot, and Baladad, praying for nominal, moral, exemplary, and actual damages plus litigation costs and attorney’s fees
- Respondents moved to dismiss for alleged failure to exhaust administrative remedies before CHED; RTC granted the motion and dismissed the complaint
Issues Presented
- Whether the doctrine of exhaustion of administrative remedies applies to a civil action for damages under the Civil Code’s human relations provisions
- Whether a prior declaration of invalidity of a school administrative policy by CHED is a prerequisite to a damages action in court
- Whether CHED has exclusive original jurisdiction over actions for damages based on alleged violation of Civil Code human relations provisions
- Implied issue: whether the Complaint as filed states sufficient causes of action
Ruling of the Regional Trial Court
- Held that Section 54 of the Education Act of 1982 vested supervisory and regulatory jurisdiction ove