G.R. No. 85839 October 19, 1989
EMMANUEL S. LICUP, NOEL F. TABASA, and JOEL MARC CAIRO, petitioners, vs. THE UNIVERSITY OF SAN CARLOS (USC), FR. RODERICK SALAZAR, JR., SVD, in his capacity as President of USC, FR. EDUARDO R. ROCHA, SVD, in his capacity as Chairman of Disciplinary Board of USC, respondents.

FACTS

Petitioners, student leaders at the University of San Carlos (USC), led protests against a 9% tuition fee increase announced by the university for the 1988-1989 school year. They argued the increase was unnecessary to fund mandatory teacher salary increases under R.A. No. 6640 . Their demonstrations escalated to blockading the university’s entrance and exit gates, preventing other students from attending classes. In response, USC initiated administrative proceedings against them for violating university rules. A Formal Inquiry Committee, composed of faculty members including a former Court of Appeals Justice, was created to investigate. Petitioners participated in the investigation with counsel but questioned the committee’s impartiality and the validity of the university handbook rules. The committee found them guilty, and the Disciplinary Board imposed the penalty of non-readmission for the second semester.

ISSUE

Whether the University of San Carlos violated the petitioners’ right to due process in the administrative proceedings that led to their non-readmission.

RULING

The Supreme Court dismissed the petition, finding no due process violation. The Court held that the petitioners were afforded due process. They were given adequate notice of the charges, represented by counsel during the investigation, and allowed to present their evidence before a duly constituted committee. The Court found the investigation to be fair and impartial, noting the committee’s respectable composition. The imputation of bias was unsupported by the record. The penalty of non-readmission, as opposed to outright expulsion, was deemed the most lenient sanction available under the circumstances for their infraction, which involved disruptive and non-peaceful demonstrations that impeded the academic rights of other students. The Court balanced the students’ right to education against the university’s academic freedom and right to maintain discipline within its premises. It reiterated the doctrine that when a student commits a serious breach of discipline, the university’s discretionary authority in imposing academic sanctions should generally not be interfered with by the courts, provided due process is observed. The university acted within its rights to uphold order and its academic mission.