GR 99327; (May, 1993) (Digest)
G.R. No. 99327 May 27, 1993
ATENEO DE MANILA UNIVERSITY, FATHER JOAQUIN BERNAS, S. J., DEAN CYNTHIA ROXAS-DEL CASTILLO, JUDGE RUPERTO KAPUNAN, JR., JUSTICE VENICIO ESCOLIN, FISCAL MIGUEL ALBAR, ATTYS. MARCOS HERRAS, FERDINAND CASIS, JOSE CLARO TESORO, RAMON CAGUIOA, and RAMON ERENETA, petitioners,
vs.
HON. IGNACIO M. CAPULONG, Presiding Judge of the RTC-Makati, Br. 134, ZOSIMO MENDOZA, JR., ERNEST MONTECILLO, ADEL ABAS, JOSEPH LLEDO, AMADO SABBAN, DALMACIO LIM JR., MANUEL ESCONA and JUDE FERNANDEZ, respondents.
FACTS
The case arose from a hazing incident during the initiation rites of the Aquila Legis fraternity at the Ateneo Law School on February 8-10, 1991, which resulted in the death of freshman Leonardo “Lennie” H. Villa and the hospitalization of another freshman, Bienvenido Marquez. The Ateneo de Manila University, through Dean Cynthia Roxas-del Castillo, created a Joint Administration-Faculty-Student Investigating Committee, which found a prima facie case against the respondent students for violating Rule No. 3 of the Ateneo Law School Rules on Discipline prohibiting participation in hazing. A Disciplinary Board was subsequently formed. The Board found the respondent students, who acted as master auxiliaries (“auxies”) during the rites, guilty of hazing by active participation or acquiescence. The Board left the imposition of the penalty to the University Administration. University President Fr. Joaquin Bernas, S.J., imposed the penalty of dismissal on all respondent students. The respondent students filed a petition for certiorari, prohibition, and mandamus with the Regional Trial Court of Makati, alleging lack of due process in their dismissal and seeking to enjoin the implementation of the penalty. The trial court issued a temporary restraining order and later a writ of preliminary injunction.
ISSUE
Whether the respondent students were accorded due process in the disciplinary proceedings conducted by the Ateneo de Manila University that led to their dismissal.
RULING
The Supreme Court ruled that the respondent students were accorded due process. The Court emphasized the academic freedom of institutions of higher learning, which includes the right to establish disciplinary rules and to administer them. The disciplinary proceedings conducted by the University were found to be fair and in accordance with the requirements of due process in administrative cases. The students were given notice of the charges, the opportunity to present their side, and the hearings were conducted in a summary manner consistent with established jurisprudence (Guzman v. National University). The Court held that the essence of due process in administrative proceedings is the opportunity to be heard, and this was satisfied. The Court set aside the writ of preliminary injunction issued by the trial court and made it permanent, thereby upholding the University’s dismissal of the respondent students.