Title
Supreme Court
Spouses Crystal vs. Cebu International School
Case
G.R. No. 135433
Decision Date
Apr 4, 2001
Parents challenged Cebu International School's P50,000 land purchase deposit for enrollment, arguing it was illegal. Courts ruled the deposit valid, denying admission without payment, as enrollment rights in private schools are not absolute.

Case Summary (G.R. No. 206972)

Core Issue and Legal Basis

The primary issue at hand revolves around the denial of a writ of preliminary injunction that the petitioners sought to compel the school to enroll their children without the payment of a contested land purchase deposit. The legal basis for the decision hinges on the provisions laid out in the 1987 Constitution of the Philippines regarding the right to education and the legality of school policies.

Background of the Case

Petitioners had previously enrolled their children in CIS, and upon their attempt to enroll Monica Claire and Frances Lorraine for the school year 1996-97, faced refusal unless they paid a land purchase deposit along with their tuition fees. This deposit was later contested by the petitioners as illegal, citing violations of education laws that did not authorize such a charge.

Court Proceedings and Findings

Initially, the Regional Trial Court (RTC) denied the petitioners' motion for a preliminary injunction, stating that the petitioners failed to demonstrate a clear right to be enrolled, as they had not paid the required fees on time. The Court of Appeals upheld this ruling, determining that the petitioners had not shown that they held any unmistakable right that warranted injunctive relief.

Petitioners' Arguments

The petitioners asserted that the land purchase deposit was not a legitimate condition for enrollment and highlighted their compliance with existing school policies by offering to pay the necessary tuition fees. They argued that the condition imposed by the school effectively barred their children from education rights, which should be protected under the Constitution.

School's Defense

The respondents maintained that the land purchase deposit was a valid and necessary financial requirement, communicated earlier to the parents. They contended that failure to comply with this requirement hindered the admission of the children, and argued that the school had followed appropriate procedures for imposing such a charge which had been agreed upon in prior consultations with parents.

Court's Interpretation on Enrollment Rights

The Court affirmed the principle that the right to enroll in a private educational institution is not absolute but conditioned upon compliance with reasonable admission r

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