G.R. No. L-68288 July 11, 1986
DIOSDADO GUZMAN, ULYSSES URBIZTONDO, and ARIEL RAMACULA, petitioners, vs. NATIONAL UNIVERSITY and DOMINGO L. JHOCSON in his capacity as President of National University, respondents.

FACTS

Petitioners, students of respondent National University, sought relief from the school’s refusal to allow their re-enrollment for the first semester of the 1984-1985 academic year. They alleged this refusal was due to their participation in peaceful mass actions within university premises, constituting an expulsion without due process, as their right to enroll was withheld without formal charges or a hearing. The petitioners invoked constitutional rights and cited a prior case involving the same university. Respondents countered that the failure to enroll was the petitioners’ own fault, citing closed enrollment periods, poor academic standing, and disruptive activities. They specifically noted petitioner Guzman’s involvement in a pending criminal case for malicious mischief and a civil case for damages, and asserted that all petitioners had continued to lead or participate in campus activities that disturbed classes without prior permits, contrary to a spirit of a prior Supreme Court admonition.

ISSUE

Whether the respondent university’s refusal to re-enroll the petitioners, allegedly due to their participation in mass actions and other conduct, constitutes an expulsion without due process of law.

RULING

Yes. The Supreme Court granted the petition, directing the respondents to allow the petitioners to re-enroll or continue their studies. The Court held that the act of refusing enrollment, when based on the students’ past misconduct, is tantamount to an expulsion or dismissal, which is a disciplinary sanction. Such a sanction cannot be imposed without observance of procedural due process. The right to education is constitutionally protected, and while educational institutions possess the academic freedom to set rules, including those on student discipline, this authority must be exercised within the bounds of fair play. The Court clarified that due process in student disciplinary cases does not require judicial-type proceedings but mandates minimum standards: (1) written notice of the charges; (2) the right to answer with counsel; (3) disclosure of the evidence against them; (4) the right to present their own evidence; and (5) consideration of the evidence by a designated investigating body. Since the petitioners were effectively excluded without being accorded these safeguards, the university’s action was invalid. The directive to allow enrollment was made without prejudice to the university’s right to institute proper disciplinary proceedings in accordance with these due process standards.