Title
Unciano Paramedical College, Inc. vs. Court of Appeals
Case
G.R. No. 100335
Decision Date
Apr 7, 1993
Students barred from re-enrollment after proposing a student council; court ruled Non doctrine non-retroactive, upholding school's reliance on Alcuaz doctrine.
school enrollment
termination of contract
new doctrine
A

Case Summary (G.R. No. 100335)

Factual Background

Private respondents Elena Villegas and Ted Magallanes, through their mothers, alleged that during the latter part of July 1989 they and other students circulated a petition to organize a student council and secured at least one hundred and eighty signatures. The students claimed that school authorities, through Dean Dr. Evelyn Moral and Dean Laureana Vitug, repeatedly admonished and threatened them with refusal of enrollment if they persisted with the student council. The students alleged further that they were accused of membership in student activist organizations and other misconduct without disclosure of proof and that school officials advised them to secure their honorable dismissal or face being marked expelled. The petitioners allegedly refused re-enrollment by administrative decision of the Board of Trustees communicated in December 1989.

Trial Court Proceedings

On May 16, 1990 the trial court issued a temporary restraining order effective May 17, 1990, and set hearing for a preliminary mandatory injunction. After hearing, the trial court found that private respondents would suffer irreparable injury if not allowed to enroll because they would miss another semester, while the injuries alleged by petitioners were speculative. The trial court therefore granted a preliminary mandatory injunction ordering petitioners to allow private respondents to enroll for the first semester of school year 1990-1991 upon filing a bond of P2,000 each. The writ of preliminary mandatory injunction issued on June 11, 1990, and the trial court denied petitioners' motion for reconsideration on June 13, 1990.

Court of Appeals Proceedings and Ruling

Petitioners elevated the matter to the Court of Appeals by a petition for certiorari and prohibition with preliminary injunction. The Court of Appeals dismissed the petition on February 7, 1991 for lack of merit and denied reconsideration on June 3, 1991. The appellate court analyzed controlling Supreme Court precedents, contrasting the earlier ALCUAZ, et al. vs. Philippine School of Business Administration, Quezon City Branch (PSBA), et al. decision of May 2, 1988 with the later Ariel Non, et al. vs. Hon. Sancho Dames II, et al. decision of May 20, 1990, and applied the latter in holding that the school could not rely on the termination-of-contract theory to refuse re-enrollment.

Legal Issue Presented

The sole issue posed by petitioners to the Supreme Court was whether the doctrine announced in Ariel Non, et al. vs. Hon. Sancho Dames II, et al. should be applied retroactively so as to govern and invalidate legal effects of incidents that occurred prior to its promulgation and that were valid under the then-prevailing ALCUAZ doctrine.

Petitioners' Arguments

Petitioners argued that at the time the termination-of-contract determination occurred the Supreme Court had already announced the ALCUAZ doctrine on May 2, 1988, which recognized that the contractual relationship between student and school terminated at the end of the semester. Petitioners contended that they relied in good faith on that doctrine and that the later abandonment of ALCUAZ in Non should not be applied retroactively to penalize conduct that was lawful under the earlier precedent. They invoked the rule that a new judicial doctrine should ordinarily be applied prospectively to avoid oppression of those who acted under the old rule, citing People v. Jabinal and other authorities.

Respondents' Allegations and Relief Sought

Private respondents sought injunctive relief and damages. They alleged denial of due process in the threatened and actual refusal of re-enrollment and characterized the school's actions as a willful and unlawful invasion of their rights. They invoked the presumption of the right to continue enrollment under the Manual of Regulations for Private Schools and Batas Pambansa Blg. 232, Section 9, which recognizes the right of students to continue their course except for academic or disciplinary causes, and sought a preliminary mandatory injunction to restore their enrollment pending final determination.

Supreme Court's Ruling and Disposition

The Supreme Court granted the petition. It set aside the decision of the Court of Appeals dated February 7, 1991 and its resolution dated June 3, 1991. The Supreme Court likewise set aside the trial court orders of June 4 and June 13, 1990 and the writ of preliminary mandatory injunction. Judgment was rendered for petitioners.

Supreme Court's Legal Reasoning

The Court agreed with petitioners that the Ariel Non doctrine should not be given retroactive effect to govern cases that arose before its promulgation on May 20, 1990. The Court observed that the termination-of-contract theory articulated in ALCUAZ had been the prevailing rule when petitioners acted and when the underlying administrative decisions occurred. The Court cited prior decisions, including People v. Jabinal and National Service Corporation, et al. v. NLRC, to reaffirm the principle that the overruling of a prior doctrine ordinarily operates prospectively and should not unduly oppress parties who relied on the old rule. On the issuance of the preliminary mandatory injunction, the Court reli

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