G.R. No. 127980. December 19, 2007.
DE LA SALLE UNIVERSITY, INC., et al., petitioners, vs. THE COURT OF APPEALS, et al., respondents.

FACTS

Private respondents, students and members of the Tau Gamma Phi fraternity, were involved in two violent incidents on March 29, 1995. The first incident involved the physical assault of petitioner James Yap, a member of the rival Domino Lux fraternity, by a group including the respondents near the DLSU campus. The second incident occurred later that same day, where the respondents were involved in another mauling of Yap’s fraternity brothers. Following an investigation, the DLSU-CSB Joint Discipline Board found the private respondents guilty of misconduct and imposed the penalty of expulsion.
The expelled students filed a case before the Regional Trial Court (RTC), which issued a writ of preliminary injunction ordering their readmission. The RTC later rendered a decision modifying the penalty from expulsion to exclusion for one academic year. The Commission on Higher Education (CHED), in the exercise of its appellate jurisdiction under Batas Pambansa Blg. 232, also modified the penalty. DLSU elevated the case to the Court of Appeals, which dismissed the petition. DLSU then filed the present petition before the Supreme Court.

ISSUE

Whether the Court of Appeals erred in upholding the RTC’s and CHED’s modification of the penalty imposed by DLSU on the erring students.

RULING

The Supreme Court granted the petition and reversed the assailed rulings. The Court held that the lower courts and CHED committed grave abuse of discretion in substituting their judgment for that of DLSU’s academic authorities regarding the appropriate disciplinary penalty. The legal logic rests on the constitutional guarantee of academic freedom, which grants educational institutions the right to set their own standards of conduct and to determine, within reasonable bounds, who may be admitted to study.
The Court emphasized that the imposition of disciplinary sanctions is an integral part of a school’s academic freedom and its responsibility to maintain a conducive educational environment. The findings of the DLSU Discipline Board were supported by substantial evidence, establishing the students’ participation in violent acts that disrupted campus order and safety. While the right to education is constitutionally protected, it is not absolute and must yield to the equally vital right of schools to enforce discipline and ensure the welfare of their student body. The penalty of expulsion, being a consequence of serious misconduct, was within the university’s discretionary authority and was not imposed arbitrarily. Therefore, the judicial and executive branches overstepped their bounds by interfering with this academic prerogative.