Case Summary (G.R. No. 132344)
Key Dates
Enrollment: 1984–1988
Removal exam application: February 1, 1988
Removal exam taken: March 28, 1988
Grade submission (failing): May 30, 1988
Commencement and hooding: April 16, 1988
Trial court decision: September 4, 1990
Court of Appeals decision: October 10, 1997
Supreme Court decision: February 17, 2000
Applicable Law
1987 Philippine Constitution (post-1990 decision)
Civil Code of the Philippines, Articles 19 and 20 (duty of care, good faith, and indemnity for negligent acts)
Rules of Court, Rule 45 (petition for review)
Facts
- Jader obtained an “Inc.” grade in Practice Court I for the first semester of 1987–1988 after missing the regular exam.
- He applied and paid to remove the incomplete grade, took the removal exam on March 28, 1988, and awaited the result.
- UE’s faculty deliberated and prepared a tentative graduate list, which included Jader with annotations of deficiencies, but did not remove his name.
- Jader participated in the April 16, 1988 commencement exercises, received symbolic diploma, and held a celebratory reception.
- He enrolled in bar review classes, prepared for the 1988 bar exam, then learned of his failing grade and was barred from taking the bar.
Issue
Whether an educational institution is civilly liable for damages when it negligently misleads a student into believing he has fulfilled graduation requirements.
Trial Court Decision
The Regional Trial Court found UE negligent for failing to inform Jader of his incomplete grade before commencement. It awarded P35,470.00 actual damages, P5,000.00 attorney’s fees, and interest from filing.
Court of Appeals Decision
Affirmed the trial court’s liability and awards, adding P50,000.00 moral damages. Costs were cast against UE.
Supreme Court Ruling
Contractual Relationship and Duty.
- Enrollment creates a contract between school and student. Professors act as agents of the school.
- The institution has an exclusive duty to inform students promptly of academic standing and deficiencies.
Negligence and Good Faith.
- UE delayed notification of the failing grade until after Jader’s bar preparation, breaching its obligation of good faith and due care under Article 19, Civil Code.
- Exclusive control over grade submission makes UE liable for its professors’ delays.
Proximate Cause and Reliance.
- Reasonable reliance on commencement inclusion justified Jader’s belief he was eligible for the bar.
- UE’s conscious indifference amounted to an abuse of right.
Case Syllabus (G.R. No. 132344)
Facts of the Case
- Respondent was enrolled in University of the East College of Law from 1984 to 1988.
- In the first semester of SY 1987–1988, he failed to take the final examination in Practice Court I and was given an “Incomplete” grade.
- He filed for removal of the incomplete grade on February 1, 1988; the dean approved after payment of fees, and respondent took the exam on March 28, 1988.
- On May 30, 1988, Professor Ortega submitted a failing grade (5) for Practice Court I.
- Meanwhile, the College’s faculty deliberated on graduation candidates and included respondent’s name in the tentative list with annotations noting deficiencies.
- The invitation to the 35th commencement exercises (April 16, 1988) bore respondent’s name among candidates, with a footnote that the list was “tentative” and subject to completion of requirements.
- At the ceremony, respondent received the hood and a symbolic diploma; photographs and a celebratory party followed.
- Respondent took leave from employment and enrolled in a bar review class, only to learn later of his deficiency and dropped out, thus missing the 1988 bar examinations.
Procedural History
- Respondent sued UE for damages (moral shock, mental anguish, besmirched reputation, sleepless nights, unrealized income, attorney’s fees, costs).
- UE denied liability, asserting no representation that respondent had completed all requirements.
- RTC (Branch IX, Manila) found UE negligent, awarded P35,470 actual damages, P5,000 attorney’s fees, interest, and costs; dismissed