GR 82499; (October, 1989) (Digest)
G.R. No. 82499 October 13, 1989
CAPITOL MEDICAL CENTER, INC., and DRA. THELMA NAVARRETE CLEMENTE, petitioners, vs. THE COURT OF APPEALS, HON. IGNACIO SALVADOR, in his capacity as Presiding Judge of Branch 77 of the Regional Trial Court of the National Capital Region (Quezon City), MONINA REYES-VALENZUELA, PABLO L. DAMASO, LINA M. ABLANG, MA. TERESITA ROQUE, AMBROSIO LAZOL, DIOSDADO YAP, FLORDELIZA SINGSON, SARAH P. PELOBELLO JOEL H. GILLEGO, AGNES A. DE VEGA, NORAIDA Y. MAGALONG, AUGENCIO PAPA, IMELDA SIMBILLO, MAXIMO CALDERON and ROSALIE FLORIDA C. ILAGA, respondents.
FACTS
Petitioner Capitol Medical Center, Inc. (CMCI) operated the Capitol Medical Center College (CMCC). During the first semester of the 1987-88 school year, a dispute arose between the college administration and its faculty over demands for vacation and sick leave benefits. The CMCI Board, foreseeing uncontrollable antagonism that could lead to mass actions endangering the adjacent hospital’s patients, authorized its president, Dr. Thelma Navarrete-Clemente, to close the college at the end of the first semester if the situation deteriorated.
The conflict escalated. Faculty members unilaterally postponed final examinations, and students joined them in noisy demonstrations in front of the hospital. Citing the disturbance to hospital peace and potential danger to patients, the CMCI Board held an emergency meeting and resolved to close the school permanently at the end of the first semester. The administration posted announcements of the closure, advised students to transfer, and formally notified the Department of Education, Culture and Sports (DECS).
ISSUE
Whether a school that closed after due notice to the DECS, following disruptive strikes by its teachers and students, can be compelled by the courts to reopen and readmit the striking students.
RULING
The Supreme Court ruled in favor of the petitioners, setting aside the lower court’s orders. The Court held that the Regional Trial Court gravely abused its discretion in issuing a writ of preliminary mandatory injunction to compel the school to reopen. The legal logic centered on the absence of a clear legal right on the part of the students and the reciprocal nature of any implied contractual relationship.
The Court found no law, including the Education Act of 1982 or the Manual of Regulations for Private Schools, that obligates a school to remain operational until all its students complete their courses. Conversely, a student is not legally bound to stay until graduation and may transfer at will. Analyzing the relationship as potentially an implied contract, the Court emphasized its reciprocal nature. The school’s obligation to educate presupposes the student’s obligation to study and obey school rules. By joining demonstrations and refusing to take examinations, the students breached this implied contract. The school’s consequent decision to close was a justified response to the breach and was neither arbitrary nor unfair. The Court concluded that the students had no clear legal right to re-enroll in a defunct institution, and the school had no corresponding obligation to reopen for them.