G.R. No. 76353 September 29, 1989
SOPHIA ALCUAZ, ET AL., petitioners, vs. PHILIPPINE SCHOOL OF BUSINESS ADMINISTRATION, QUEZON CITY BRANCH (PSBA), ET AL., respondents.

FACTS

The case originated from student demonstrations at the Philippine School of Business Administration (PSBA) in Quezon City. The petitioners, students of PSBA, participated in rallies to air grievances, which the school administration deemed disruptive. Consequently, the school refused the re-enrollment of several students for the subsequent semester. The students filed a petition, arguing that their right to due process was violated by this refusal, which they contended was punitive and not based on academic grounds.
A prior Decision by the Court’s Second Division, dated May 2, 1988, had ruled that the relationship between the student and the school was contractual, with the contract being for one semester as per the school’s manual. Thus, after a semester ended, no existing contract bound the school to re-enroll the students, making a charge of denial of due process untenable. This ruling prompted a Motion for Reconsideration, partly focused on its implications for teacher tenure but also challenging its application to students.

ISSUE

The core issue for resolution was whether the school’s refusal to re-enroll the students, primarily due to their participation in demonstrations, constituted a valid exercise of academic freedom and contractual right or an infringement of the students’ constitutional rights to education, free speech, and peaceful assembly.

RULING

The Court, sitting En Banc, denied the Motion for Reconsideration but issued clarificatory statements. It reaffirmed the principle from its May 1988 Decision that the student-school relationship is essentially contractual per semester. The Court held that upon the expiration of a semester’s contract, the school is not obligated to renew it. Therefore, the refusal to re-enroll the students, ostensibly for the expiration of the contract and later for academic deficiency, did not constitute a denial of due process.
However, the Court took the opportunity to reiterate fundamental constitutional balances. It expressly valued the students’ right to complete their education and fully respected their rights to freedom of speech and peaceful assembly to redress grievances. It emphasized that such activities must be conducted peacefully, without intimidation, coercion, or violence. The Court stated that academic freedom demands discipline, and to hold otherwise would subvert freedom into license. The ruling thus attempted to balance the school’s contractual and academic freedom rights with the students’ constitutional rights, ultimately upholding the school’s action in this instance while setting boundaries for future conduct. Several Justices filed dissenting and separate opinions, arguing that the majority failed to adequately protect the students’ rights and established an erroneous doctrine regarding the transient nature of the student-school relationship.