GR 172138; (September, 2010) (Digest)
G.R. No. 172138; September 8, 2010
NELSON JENOSA, et al., Petitioners, vs. REV. FR. JOSE RENE C. DELARIARTE, O.S.A., and the UNIVERSITY OF SAN AGUSTIN, Respondents.
FACTS
Petitioners are students of the University of San Agustin (University) and their parents. The students were caught engaging in hazing outside school premises in November 2002. Following dialogues, a meeting was held on November 28, 2002, attended by school authorities, the students, and their parents. The parties agreed that, to avoid formal hazing charges, the student-initiators (including petitioners) would transfer to another school, while the neophytes would be suspended. The parents, including petitioners, signed the minutes of the meeting to signify conformity. Based on this agreement, the University did not convene its Committee on Student Discipline (COSD).
Subsequently, the parents reneged on the agreement. They sent letters to the University President and the Department of Education (DepEd) seeking intervention and requesting that their children be allowed to take a home study program instead of transferring. The University refused. Petitioners then filed a complaint for injunction and damages with the Regional Trial Court (RTC), assailing the Principal’s order for immediate transfer as a violation of due process since the COSD was not convened. The RTC issued a writ of preliminary injunction, ordering the University to admit the students pending the case. Petitioners later filed a second complaint for mandatory injunction to compel the release of the students’ report cards. The RTC consolidated the cases and granted relief.
ISSUE
Whether the Regional Trial Court had jurisdiction over the subject matter of the complaints for injunction filed by the students and their parents against the University.
RULING
No, the RTC had no jurisdiction. The Supreme Court affirmed the Court of Appeals’ decision dismissing the cases. The core legal principle is that courts cannot interfere with the academic and disciplinary decisions of private educational institutions, provided such decisions are exercised in good faith and within the bounds of the school’s reasonable rules and regulations. The Court emphasized the academic freedom of institutions and the contractual nature of enrollment, where students agree to abide by school rules.
The legal logic proceeds from the finding that the November 28, 2002 agreement was valid and binding. The parents voluntarily signed the minutes, and the University relied on this agreement by foregoing a formal COSD investigation. By reneging without just cause, petitioners acted in bad faith and came to court with “unclean hands,” a maxim of equity which denies relief to a party whose conduct has been inequitable or unfair regarding the controversy. Since the agreement was valid, the Principal’s order for transfer was a proper implementation thereof, not an arbitrary act requiring judicial intervention. The RTC therefore erred in taking jurisdiction and issuing injunctive relief. The proper recourse for the students, if they felt aggrieved by the school’s actions under the agreement, was not an ordinary civil action for injunction in the RTC but an appeal to the Department of Education under its administrative procedures. The Court upheld the validity of the agreement and the authority of the school to enforce it.