Facts:
This case arose from the expulsion of four student members of the Tau Gamma Phi Fraternity, namely Alvin Aguilar, James Paul Bungubung, Richard Reverente, and Roberto Valdes, Jr., by the De La Salle University (DLSU) and College of Saint Benilde (CSB) Joint Discipline Board. The expulsion was due to their involvement in two violent incidents on March 29, 1995, which resulted in injuries to members of the Domino Lux Fraternity, including petitioner James Yap. The controversy centers around the clash between the expelled students’ right to education and the university’s academic freedom.
The procedural history began with the DLSU-CSB Joint Discipline Board’s decision on May 3, 1995, expelling the involved students for violating CHED Order No. 4. The students filed motions for reconsideration, which were denied. Subsequently, Aguilar filed a petition for certiorari and injunction under Rule 65 of the Rules of Court with the Regional Trial Court (RTC) of Manila, seeking to annul the disciplinary board’s decisions. The RTC issued a Temporary Restraining Order (TRO) and then a writ of preliminary injunction against DLSU’s actions. The university appealed to the Court of Appeals (CA), which initially granted a TRO in favor of DLSU but later, through Resolution No. 181-96 by the Commission on Higher Education (CHED), decreased the penalty from expulsion to exclusion for Aguilar and the other respondents, except for one who was fully exonerated. DLSU defied CHED’s resolutions, leading to further legal battles and eventually the Supreme Court’s involvement.
Issues:
1. Whether it is the DECS or CHED which has the authority to review disciplinary actions involving students in institutions of higher education.
2. Whether DLSU’s expulsion of the students was within its rights concerning:
a. Due process
b. Academic freedom
c. Substantial evidence supporting the expulsion
3. The proportionality of the penalty of expulsion to the misdeed.
Court’s Decision:
The Supreme Court partly granted the petition. It affirmed that CHED, not DECS, has the authority over disciplinary cases in higher education institutions. It found that the students were accorded due process, DLSU possessed academic freedom in determining student admission and discipline, and the guilt of Bungubung, Reverente, and Valdes Jr. was supported by substantial evidence. However, it deemed the expulsion penalty disproportionate to the offense, affirming the CHED’s decision to modify the penalty to exclusion and ordering DLSU to issue a certificate of completion/graduation to Aguilar.
Doctrine:
– CHED has jurisdiction over disciplinary cases in institutions of higher education.
– The principle of academic freedom grants educational institutions the authority to determine admissions and enforce discipline.
– In student disciplinary actions, the required proof is substantial evidence.
Class Notes:
– Definitions and distinctions between expulsion, suspension, and exclusion as disciplinary actions under the Manual of Regulations for Private Schools.
– The standard of “substantial evidence” in administrative proceedings, including student disciplinary cases.
– The extent and limits of academic freedom regarding student discipline and admissions.
Historical Background:
The case contextualizes the balance between students’ rights to education and the autonomous right of academic institutions to govern themselves, especially regarding admissions and disciplinary actions. This decision reinforces the principle of academic freedom while emphasizing the need for proportionality in disciplinary measures. It upholds the authority of CHED over disciplinary cases in higher education, reflecting the legal and educational reforms in the Philippines aimed at ensuring quality and accessible education at all levels.
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