Case Summary (G.R. No. 169391)
Petitioner’s Claim
The petitioners alleged that the respondents unlawfully dismissed (suspended) Kim from the high school rolls for alleged fraternity membership without observing due process, and they sought moral, exemplary, and actual damages, plus attorney’s fees.
Respondents’ Position
The respondents maintained that Kim’s sanction was a suspension (not a dismissal) for violating the school’s rule prohibiting fraternities. They asserted that the prohibition derived from DECS Order No. 20, s. 1991 (applicable to public and private secondary schools) and from Letran’s duly promulgated disciplinary regulations. They further contended that due process was observed and that there was no bad faith or malice.
Factual Background
In October 2001, Letran investigated alleged fraternity recruitment among high school students. A November 2001 medical report disclosed injuries consistent with hazing. Four neophytes admitted membership in Tau Gamma Fraternity and identified seniors, including Kim. A security officer’s incident report listed Kim among eighteen high school members. Parents were notified in November and January conferences; Kim submitted a written denial on December 19, 2001. After meetings of the Prefect for Discipline and the Rector’s Council, Kim was suspended from January 16 to February 18, 2002. Petitioners declined to sign a conformity agreement and filed a complaint for damages before the Regional Trial Court (RTC) on January 28, 2002.
RTC Decision
The RTC held that Letran had no authority to dismiss students for fraternity membership, that the evidence was insufficient to prove Kim’s membership, and that due process was violated. It awarded petitioners P2.854 million as actual damages, P20 million as moral damages, P10 million as exemplary damages, 20% attorney’s fees, and costs.
Court of Appeals Ruling
The Court of Appeals (CA) reversed. It found that the sanction imposed was a suspension, not a dismissal; that petitioners were accorded ample opportunity to be heard; that evidence was substantial; and that there was no bad faith or malice. It dismissed the complaint for lack of merit and denied the petitioners’ motion for reconsideration.
Issue Before the Supreme Court
Whether the CA erred in setting aside the RTC decision and in holding that respondents lawfully imposed disciplinary sanctions on Kim with observance of due process and without bad faith.
Authority to Enforce Fraternity Prohibition
Under DECS Order No. 20, s. 1991, fraternities are prohibited in elementary and secondary schools—public and private—and the penalty for non-compliance is expulsion. Private schools also derive authority from the Manual of Regulations for Private Schools (Section 78) and the 1987 Constitution to promulgate reasonable disciplinary rules. Letran’s enrollment contract and student handbook clearly informed parents of the prohibition and its penalty (summary dismissal from the rolls).
Due Process in School Disciplinary Proceedings
The Court applied Guzman v. National University standards for student discipline: written notice of charges, opportunity to answer, knowledge of evidence, right to present evidence, and consideration by an authorized official. Summary proceedings are permitted and cross-examination is not essential. Letran noti
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Factual Background
- October 2001: Letran’s Head of Auxiliary Services, George Isleta, receives reports of fraternity recruitment among high school students and a list of alleged members.
- November 20, 2001: School physician Dr. Emmanuel Asuncion documents blunt-trauma injuries on six students, indicative of hazing.
- Four neophytes (Raphael Jay Fulgencio, Nicolai Lacson, Carlos Parilla, Isaac Gumba) admit to Tau Gamma hazing on October 3, 2001, and identify senior members including Emerson “Kim” Go.
- Security officer Gerardo Manipon reports 18 high school fraternity members, including Kim.
- November 23, 2001: Assistant Prefect for Discipline Albert Rosarda informs Mrs. Go of Kim’s alleged fraternity membership; Kim denies membership in a December 19, 2001 written statement.
- Notices dated December 19, 2001 and January 8, 2002 schedule parent-student conferences; petitioners fail to attend the first and Mrs. Go alone attends the second on January 15, 2002.
- January 10, 2002: Fr. Jose Rhommel Hernandez recommends dismissal of fraternity members; Father Rector Fr. Edwin Lao modifies sanction to suspension (January 16–February 18, 2002), later deferred to January 21 for an exam.
- Petitioners refuse to sign pro-forma agreement, contest findings and due process, and file a complaint for damages on January 28, 2002 (RTC Civil Case No. C-19938).
Procedural History
- RTC (Branch 131, Caloocan City) finds respondents violated due process, evidence insufficient to prove membership, and Letran lacks authority to dismiss; awards actual (₱2,854,000), moral (₱20,000,000), exemplary (₱10,000,000) damages, attorney’s fees (20% of award), and costs.
- Court of Appeals (CA-G.R. CV No. 80349) reverses and sets aside RTC decision, ruling due process was observed, evidence was substantial, and no bad faith existed; denies petitioners’ motion for reconsideration.
- Petitioners file a Rule 45 petition for review on certiorari in the Supreme Court.