Case Summary (G.R. No. 162299)
Factual Background
On March 18, 2002, Olairez and Rebucal filed for injunctive relief in the RTC of Baguio City (Civil Case No. 5191-R) to enjoin enforcement of the revised COWE allegedly imposed without basis in SLU’s student handbook. Banta and Badecao later intervened. The trial court granted a preliminary injunction on April 9, 2002 and allowed them to participate in graduation rites.
RTC Judgment on Merits
On July 16, 2003, the RTC declared the group graduates of SLU’s College of Medicine, citing CHED’s certification of course completion and SLU’s own conduct in permitting commencement participation. The court ordered SLU to issue clearances, diplomas, transcripts, stop pressuring internship-granting bodies, and dismissed all damage claims.
Indirect Contempt Proceedings in RTC
After SLU filed a notice of appeal, the students on July 17, 2003 moved to cite SLU in indirect contempt for noncompliance. The RTC scheduled a show-cause hearing, issued a writ of execution on July 18, 2003, and on July 23, 2003 found Dean Dacanay and SLU officials guilty of indirect contempt under Rule 71, sentencing fines and conditioning the students’ board-exam eligibility on enforcement.
CA Dismissal of Certiorari Petition
SLU filed a Rule 65 certiorari petition before the Court of Appeals (CA-SP-78127), challenging the contempt show-cause order, writ of execution, and related orders. On November 18, 2003 and February 10, 2004, the CA dismissed the petition for failure to file a prior motion for reconsideration, holding that remedy was available in the trial court.
CA Reversal of Contempt Ruling
SLU’s appeal from the July 23, 2003 contempt order (CA-CR-27861) resulted in the CA’s April 7, 2006 Decision and September 11, 2006 Resolution recalling and setting aside the contempt finding. The CA held SLU was denied reasonable opportunity to be heard, violating due process under Rule 71.
Issues on Review in G.R. No. 162299
- Whether the CA erred in dismissing SLU’s Rule 65 petition on grounds of appeal pendency.
- Whether the CA erred in requiring a motion for reconsideration before entertaining certiorari.
Issues on Review in G.R. No. 174758
- Whether the CA abused discretion in finding violation of the three-day notice rule under Rule 15, § 4.
- Whether SLU was denied due process in the contempt proceedings.
- Whether the students’ initial motion sufficed as a motion for execution.
Supreme Court Analysis – Motion for Reconsideration Requirement
Under Rule 65, a motion for reconsideration is generally required before certiorari, serving to allow the lower court to correct errors. Exceptions exist—e.g., patent nullity or urgency—but SLU failed to establish any applicable exception. The 1987 Constitution demands strict compliance with procedural rules to ensure orderly justice; permitting SLU’s omission would undermine that discipline.
Supreme Court Analy
...continue readingCase Syllabus (G.R. No. 162299)
Procedural History
- Consolidation of two petitions for review on certiorari under Rule 45: G.R. No. 162299 (SLU et al. vs. Olairez et al. and CA) and G.R. No. 174758 (Olairez et al. vs. SLU et al.).
- G.R. 162299 challenges CA resolutions (Nov 18, 2003; Feb 10, 2004) dismissing SLU’s certiorari under Rule 65 against various RTC orders, a writ of execution, and a contempt directive.
- G.R. 174758 assails the CA’s April 7, 2006 Decision and Sept 11, 2006 Resolution reversing the RTC’s July 23, 2003 indirect‐contempt ruling against SLU and its officials.
Factual Antecedents
- Saint Louis University (SLU) is a Baguio City institution offering medicine among other courses.
- Respondents Olairez, Rebucal, Banta, and Badecao were fourth‐year SLU medical students (Batch 2002).
- March 18, 2002: Olairez and Rebucal filed a complaint in RTC Baguio (Civil Case No. 5191-R) to enjoin enforcement of a revised Comprehensive Oral and Written Examination (COWE) implemented by newly designated Dean Dacanay.
- Revised COWE added Orals 1 and 2 plus extra clerkship months, allegedly beyond SLU’s Student Handbook and delaying graduation.
- Jenny Banta and Brando Badecao intervened; a preliminary injunction issued (Apr 9, 2002) barring enforcement of the Revised COWE.
- Petitioners completed academic requirements, marched in ceremonies, received symbolic diplomas, and began internship despite pending dispute.
RTC Decision on Merits (July 16, 2003)
- Declared Olairez group as official SLU graduates in medicine.
- Found Revised COWE moot and academic based on CHED certification and SLU’s allowance to participate in commencement.
- Ordered SLU and Dean Dacanay to:
• Sign clearances and forward final grades to Registrar.
• Issue certificate of graduation, diploma, transcripts, and registry entries.
• Cease pressure on APMC and Baguio General Hospital regarding internship permits. - Dismissed all claims for damages and attorney’s fees, finding good faith on both