G.R. No. L-56180 October 16, 1986
ATENEO DE MANILA UNIVERSITY, petitioner, vs. COURT OF APPEALS, and SPOUSES ROMEO G. GUANZON and TERESITA REGALADO, respondents.

FACTS

Juan Ramon Guanzon, a first-year student and boarder at Ateneo de Manila University, was accused by a cafeteria waitress of unbecoming conduct. The complaint alleged that on December 12, 1967, after being told to wait for his food, Guanzon uttered bad words, threatened the waitress, and struck her on the left temple. The university conducted an investigation and subsequently dismissed Guanzon from the institution.
The dismissal prompted Guanzon’s parents to file a complaint for damages against the university in the Court of First Instance of Negros Occidental. They alleged that their son was expelled without a fair trial, violating his right to due process, and that this caused them actual, moral, and exemplary damages. The trial court ruled in favor of the parents, awarding damages and attorney’s fees. The Court of Appeals initially reversed this decision but, upon a motion for reconsideration heard by a special division of five, reinstated the trial court’s ruling.

ISSUE

The primary issues were: (1) whether the university afforded Juan Ramon Guanzon due process in the disciplinary proceedings; (2) whether the parents’ judicial action violated the rule on exhaustion of administrative remedies; and (3) whether the award of damages was proper.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals’ resolution and reinstating its initial decision which had dismissed the complaint. The Court held that the university accorded the student due process. The disciplinary process was set up to protect student privacy, and the investigation provided Guanzon an opportunity to explain his side. The penalty of dismissal was based on reasonable rules applicable to all students for such misconduct, which the Court characterized as a serious breach of civility and respect.
On the procedural issue, the Court ruled that the action for damages under the Civil Code was a purely legal question within the jurisdiction of civil courts. There was no need to exhaust administrative remedies by awaiting a final decision from the Office of the President on the related administrative appeal, as the damage suit was a separate cause of action.
Finally, the Court found no basis for the award of damages. The university acted in good faith, without malice or improper motive. The student was not deprived of education, as he requested and was granted an honorable dismissal, received a tuition refund, and subsequently enrolled in another school. Any embarrassment suffered by the parents resulted from their son’s own misconduct, not from any wrongful act of the university.