### Facts:
This case revolves around a conflict that arose from the publication of certain articles and images in the September-October 1994 issue of the Miriam College school paper, Chi-Rho, and its literary magazine. The contents were deemed “obscene,” “vulgar,” “indecent,” “gross,” “sexually explicit,” and “injurious to young readers” by some members of the Miriam College community. The controversial issue included a fictional story titled “Kaskas” and various poems with themes of sexuality. Following the publication, students involved with Chi-Rho, including its editors and contributors, were subjected to disciplinary actions by the Miriam College Discipline Committee for allegedly violating regulations in the student handbook.
The students contested the jurisdiction of the Miriam College Discipline Committee over their case, asserting that the Committee was not impartial and had prejudged the issue. They sought to transfer the case to the Regional Office of the Department of Education, Culture, and Sports (DECS), citing Republic Act No. 7079 (Campus Journalism Act) which provides protection for campus journalists. The College, however, proceeded with its investigation and eventually imposed sanctions ranging from suspension to expulsion on the students involved.
The students then filed a petition for prohibition and certiorari with a Regional Trial Court (RTC), which was ultimately dismissed on the ground that the DECS Regional Office—and not the RTC—had jurisdiction over the case, per DECS Order No. 94, Series of 1992. The case was then brought to the Supreme Court of the Philippines on a petition by Miriam College after the Court of Appeals declared the actions against the students void.
### Issues:
1. Whether the case had become moot.
2. Jurisdiction of the trial court over the petition filed by the students.
3. The power of Miriam College to suspend or dismiss the respondent students.
4. Jurisdiction over complaints against the students.
### Court’s Decision:
The Supreme Court ruled that the case was not moot, as Miriam College did not enforce the Temporary Restraining Order issued by the Court of Appeals, which would have allowed the students to seek readmission. The Court further held that the Miriam College had the authority to discipline its students, including the imposition of sanctions such as suspension or expulsion, in line with institutional academic freedom as guaranteed by the Constitution. Thus, Miriam College was within its rights to discipline the students through its internal processes. The Court reversed the decision of the Court of Appeals and directed Miriam College to readmit Joel Tan, whose suspension period had already lapsed.
### Doctrine:
The decision established that educational institutions have the inherent right and duty to maintain discipline among students as part of their academic freedom, which includes “who may be admitted to study” and “how it shall be taught.” However, any disciplinary action must not infringe on the constitutional rights of students, specifically the right to free speech, except in cases where the speech “materially disrupts class work or involves substantial disorder or invasion of the rights of others.”
### Class Notes:
– Academic Freedom: Right of educational institutions to decide on admission, curriculum, teaching methods, and discipline of students.
– Free Speech of Students: Students do not lose their constitutional rights to free speech within educational premises, but this right is balanced against the educational institution’s right to maintain order and discipline.
– Jurisdiction in Disciplinary Cases: The educational institution has the primary jurisdiction over disciplinary cases involving its students, consistent with its academic freedom.
– Republic Act No. 7079: Protects campus journalists from being expelled or suspended solely on the basis of their published work, provided it does not materially disrupt educational activities or infringe on the rights of others.
### Historical Background:
This case highlights the tension between the constitutional rights of students, particularly free speech and freedom of expression, and the authority of educational institutions to discipline students to maintain an orderly educational environment. It demonstrates the legal recognition of academic freedom as an essential aspect of educational autonomy, balanced against the protections afforded to students under Philippine law.
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