G.R. No. 132344 February 17, 2000
UNIVERSITY OF THE EAST, petitioner, vs. ROMEO A. JADER, respondent.

FACTS

Respondent Romeo Jader was a law student at the University of the East (UE). In his final year, he received an incomplete grade in Practice Court I. He later took a removal examination but received a failing grade of five. Despite this deficiency, UE included Jader’s name in the tentative list of candidates for graduation and in the official invitation for the 1988 commencement ceremonies. Jader participated fully in the graduation rites, where he went on stage, was hooded, and was handed a symbolic rolled diploma. Believing he had graduated, he resigned from his job, enrolled in a bar review course, and prepared for the bar exams. He subsequently discovered his failing grade and was unable to take the bar examination.
Jader filed a complaint for damages against UE, alleging he suffered moral shock, mental anguish, and besmirched reputation due to UE’s negligence in misleading him about his academic status. The Regional Trial Court ruled in Jader’s favor, awarding actual damages and attorney’s fees. The Court of Appeals affirmed but added an award for moral damages. UE appealed to the Supreme Court, arguing that Jader’s own negligence in not verifying his grade was the proximate cause of his damages.

ISSUE

May an educational institution be held liable for damages for misleading a student into believing he had satisfied all graduation requirements?

RULING

Yes, the Supreme Court held UE liable for damages, but deleted the award for moral damages. The Court affirmed the finding that a contract of education exists between the school and the student. Under this contract, it is the school’s primary obligation to timely and accurately inform the student of his academic status, including any deficiencies. The school’s agents, such as professors, administer this obligation. UE breached this duty when it included Jader’s name in the graduation list and allowed him to participate in the commencement ceremonies without verifying that he had cleared his failing grade. This official act led Jader to reasonably believe he was eligible to graduate and to incur expenses in preparation for the bar exams.
However, the Court modified the CA decision by deleting the award of moral damages. It ruled that while UE was negligent, Jader also failed in his responsibility to ensure his academic records were in order. His own contributory negligence in not verifying his grade from the professor before making significant life changes precluded an award for moral shock and anguish. Thus, UE was only liable for the actual damages (P35,470.00 with interest) and attorney’s fees (P5,000.00) proven to have been incurred by Jader in reliance on UE’s misleading actions.