G.R. No. 110280 October 12, 1993
University of the Philippines Board of Regents and Dr. Olivia C. Caoili, in her capacity as Secretary of the Board, petitioners, vs. Hon. Elsie Ligot-Telan, in her capacity as Presiding Judge of Branch 87, Regional Trial Court of Quezon City, and Ramon P. Nadal, respondents.

FACTS

The University of the Philippines (U.P.) implemented the Socialized Tuition Fee and Assistance Program (STFAP) to democratize access to education. Applicants, including respondent Ramon P. Nadal, a law student, were required to submit a sworn statement of their family’s financial status. The sworn statement warned that willful misinformation or withholding of information would be grounds for disqualification from benefits, expulsion, and reimbursement of benefits with interest. A random home investigation of Nadal’s residence revealed discrepancies: he failed to declare that he maintained a 1977 Toyota Corolla and that his mother in the U.S. had income supporting his brothers’ studies. Nadal was charged before the Student Disciplinary Tribunal (SDT) with willfully withholding information, an act of dishonesty under university rules. The SDT exonerated him regarding the car but found him guilty of withholding information about his mother’s income. The SDT imposed the penalty of expulsion and reimbursement of all STFAP benefits. The U.P. Diliman Executive Committee affirmed the decision. On appeal, the U.P. Board of Regents (BOR) modified the penalty to one-year suspension, effective immediately, plus reimbursement of all STFAP benefits with legal interest, and denied him a certification of good moral character. Nadal filed a motion for reconsideration. While this was pending, Nadal filed a petition for mandamus with the Regional Trial Court (RTC), which issued a temporary restraining order (TRO) and later a writ of preliminary injunction, directing U.P. to allow Nadal to enroll, attend classes, and take examinations. U.P. filed the instant petition, arguing that the RTC had no jurisdiction and that Nadal failed to exhaust administrative remedies.

ISSUE

Whether the Regional Trial Court had jurisdiction to entertain the petition for mandamus and issue injunctive relief against the disciplinary decision of the University of the Philippines Board of Regents.

RULING

The Supreme Court GRANTED the petition and ordered the lower court to dismiss the petition for mandamus. The Court held that the Regional Trial Court had no jurisdiction over the case. The governing law is the University of the Philippines Charter (P.D. No. 58), which grants the U.P. Board of Regents the ultimate authority over disciplinary matters. Decisions of the Board of Regents are final and executory. Judicial review of such decisions is limited to instances where the board acted with grave abuse of discretion, in excess of jurisdiction, or in violation of the petitioner’s constitutional rights. Such review is properly within the exclusive original jurisdiction of the Supreme Court via a petition for certiorari under Rule 65 of the Rules of Court, not the Regional Trial Court via mandamus. Furthermore, the Court found that Nadal failed to exhaust administrative remedies as his motion for reconsideration was still pending before the Board of Regents when he filed the court action. The Court also emphasized the importance of upholding the integrity of the STFAP program and the university’s authority to discipline its students.