University of the East vs Romeo Jader

G.R. No. 132344 – 327 SCRA 804 – Civil Law – Human Relations – Article 19 of the Civil Code

In 1987, Romeo Jader was a graduating law student at the University of the East. He failed to take the regular examination in Practice Court 1 for which he was given an incomplete grade (INC). He enrolled for the second semester as a fourth year student, and filed an application for the removal of the incomplete grade which was approved by the Dean.

In the meantime, the faculty members and the Dean met to deliberate who among the fourth year students should be allowed to graduate. Jader’s name appeared on the tentative list, he also attended the investiture ceremonies and later he gave blowout celebrations. He thereafter prepared himself for the bar examination and took review classes. However, he was not able to take the 1988 bar examinations because his academic requirements were not complete because it appears that his INC rating was not removed.

Consequently, he sued UE for damages alleging that he suffered moral shock, besmirched reputation, wounded feelings, and sleepless nights, when he was not able to take the 1988 bar examinations arising from the UE’s negligence. He prayed for an award of moral damages, unrealized income, attorney’s fees, and cost of suit.

ISSUE: Whether or not an educational institution be held liable for damages for misleading a student into believing that the latter had satisfied all the requirements for graduation when such is not the case.

HELD: Yes. The Supreme Court held that UE is liable for damages. It is the contractual obligation of the school to timely inform and furnish sufficient notice and information to each and every student as to where he or she had already complied with the entire requirement for the conferment of a degree or whether they should be included among those who will graduate. Educational institutions are duty-bound to inform the students of their academic status and not wait for the latter to inquire from the former. In doing this obligation, UE must do so in good faith as provided for by Article 19 of the Civil Code. Here, it was too late in the day for UE to inform Jader that he failed a subject. Jader already celebrated his graduation and had made preparations for the bar. The school cannot be said to have acted in good faith. In belatedly informing Jader, particularly at a time when he had already commenced preparing for the bar exams, UE cannot be said to have acted in good faith. This makes UE liable for actual damages.

But UE is not liable for moral damages. Jader could not have suffered shock, trauma and pain when he was informed that he could not graduate and will not be allowed to take the bar examinations. At the very least, it behooved on Jader to verify for himself whether he has completed all necessary requirements to be eligible for the bar examinations. As a senior law student, Jader should have been responsible enough to ensure that all his affairs, specifically those pertaining to his academic achievement, are in order.

Read full text