G.R. No. 169391; October 10, 2012
GO, and Minor EMERSON CHESTER KIM B. GO, Petitioners, vs. COLEGIO DE SAN JUAN DE LETRAN, REV. FR. EDWIN LAO, REV. FR. JOSE RHOMMEL HERNANDEZ, ALBERT ROSARDA and MA. TERESA SURATOS, Respondents.

FACTS

Petitioners, the parents of minor high school student Emerson Chester Kim B. Go, filed a complaint for damages against Colegio de San Juan de Letran and its officials. The school suspended Kim after an investigation found him to be a senior member of the Tau Gamma Fraternity, which was actively recruiting and conducting hazing rites involving Letran high school students. The investigation was triggered by a report of injuries on several students and written admissions from four neophytes who identified Kim as present at a hazing. Kim denied membership, claiming he was merely picking up a gift. The school afforded Kim the opportunity to explain, notified his parents, and held conferences. Ultimately, the school imposed a suspension, not dismissal, and arranged for make-up classes so affected fourth-year students, including Kim, could still graduate. The petitioners refused to accept the finding and the proposed agreement.
The Regional Trial Court ruled in favor of the Gos, finding the school’s evidence insufficient and its process lacking in due process, awarding moral, exemplary, and actual damages. The Court of Appeals reversed this decision. The petitioners elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the respondents are liable for damages for suspending petitioner Kim Go on the grounds of fraternity membership.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision, ruling that the respondents are not liable for damages. The legal logic rests on the academic institution’s right to discipline students and its compliance with due process. The Court found that Letran’s disciplinary rules, which prohibit fraternity membership in the high school department, are valid and reasonable. This prohibition is aligned with Department of Education policies aimed at preventing violence and hazing. The school’s investigation was thorough: it relied on medical evidence, written admissions from neophytes who identified Kim, and a security report. The process afforded to Kim satisfied the requirements of administrative due process for student discipline. He was informed of the charge, asked to explain in writing, and his parents were notified and invited to conferences. The penalty imposed was a suspension, not an expulsion, and the school took steps to mitigate its academic impact. The Court emphasized that academic institutions possess inherent authority to set disciplinary standards and that courts should not interfere with their reasonable judgments absent proof of arbitrariness. The petitioners’ claim for actual damages due to lost business opportunity was also denied for lack of sufficient factual and legal basis.