Case Summary (G.R. No. 88386)
Applicable Law
The constitutional provisions relevant to this case include Article XIV, Section 1, which stipulates the right to quality education, and Article XIV, Section 2, which mandates the State to establish and maintain a system of free public education at the elementary and high school levels. Additionally, Article XIV, Section 5 acknowledges the academic freedom enjoyed by institutions of higher learning. The case is also influenced by Republic Act No. 6655, known as the "Free Public Secondary Education Act of 1988," which encompasses state colleges and universities offering secondary education.
Background and Timeline of Events
The genesis of the UPCBHS can be traced back to 1972 when it was established as part of UP’s graduate program in education, with specific conditions that it remain self-supporting without financial reliance on UP's budget. Over the years, various reviews conducted in 1981 and 1985 raised concerns regarding the viability of UPCBHS, particularly as it had failed to serve its intended academic function and increasingly operated at a financial deficit. On January 30, 1989, the Board of Regents approved the phase-out of UPCBHS, leading to a memorandum from Dean Patricio Lazaro instructing the school not to accept new freshmen for the 1989-1990 academic year.
Legal Proceedings
Following the announcement of the phase-out, the UP College Baguio High School Foundation filed a petition for injunction against the university's Board of Regents in the Regional Trial Court of Baguio City, challenging the legality and constitutionality of the Board’s decision. Respondent Judge Ruben Ayson issued orders on May 25 and June 14, 1989, restraining the implementation of the Board's decision, prompting the petitioners to seek certiorari and a temporary restraining order from the higher courts.
Central Legal Issues
The petitioners argue that the Board's decision is an exercise of academic freedom as protected by the Constitution, asserting that the decision-making related to the operation of higher learning institutions rests within their autonomous prerogative. Conversely, respondents argue their right to free public secondary education, suggesting that the abolition of UPCBHS contravenes this constitutional guarantee and relevant legislation.
Judicial Analysis
The Supreme Court analyzed the conflict between academic freedom and the right to free public education. Academic freedom, as articulated in Article XIV, Section 5, empowers institutions like UP to establish their educational mandates without external interference, which, according to the Court, should encompass the right to phase out non-viable programs such as UPCBHS. The Court further noted that while Republic Act No.
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Case Overview
- This case involves a petition for certiorari filed by the University of the Philippines (UP), its Board of Regents, and Dean Patricio Lazaro against Hon. Judge Ruben Ayson and the UP College Baguio High School Foundation, Inc.
- The petition seeks to annul the Orders issued by Judge Ayson on May 25, 1989, and June 14, 1989, which restrained the petitioners from implementing the decision to phase out the UP College Baguio High School (UPCBHS).
- The petitioners also requested a temporary restraining order due to the urgency of the matter.
Background of the Case
- The UP Board of Regents established UPCBHS in 1972 as part of the graduate education program, intended to serve as a laboratory school for prospective teachers, with the condition that it must be self-supporting.
- In 1978, the Board of Regents created a Division of Education in UP College Baguio, which included a Department of Professional Education and a High School Department. However, the Department of Professional Education was never organized.
- Recommendations from various committees over the years, including the Committee to Review Academic Program in 1981 and the Program Review Committee in 1985, suggested the abolition of UPCBHS due to financial constraints and its failure to serve its intended purpose.
Decision to Phase Out UPCBHS
- On January 30, 1989, the UP Board of Regents approved the phase-out of UPCBHS, citing insufficient graduates qualifying for UP College