G.R. No. L-68288 – 226 Phil. 596 – 142 SCRA 699 – Political Law – Bill of Rights – Due Process – Due Process in Educational Institutions
In 1984, Diosdado Guzman and two others complained that the National University (NU) barred them from enrolling in the said university. NU argued that their failure to enroll was due to the students’ fault. It was alleged that Guzman et al spearheaded illegal mass actions within the university premises; that such mass actions were violative of school policies; that due to their mass actions, Guzman et al incurred bad grades; that Guzman et al hated NU anyway so why should they be allowed to enroll; that it is in the best interest of both parties for the students not to be enrolled.
ISSUE: Whether or not National University may not admit the Diosdado Guzman et al in the case at bar.
HELD: No. Guzman et al were deprived of due process. In the first place, NU never showed which school policies or duly published rules did Guzman et al violate upon which they may be expelled from. NU failed to show that it conducted any sort of proceedings (not necessarily a trial type one) to determine Guzman et al’s liability or alleged participation in the said mass actions.
Under the Education Act of 1982, Guzman et al, as students, have the right among others “to freely choose their field of study subject to existing curricula and to continue their course therein up to graduation, except in case of academic deficiency, or violation of disciplinary regulations.” Guzman et al were being denied this right, or being disciplined, without due process, in violation of the Manual of Regulations for Private Schools which provides that “no penalty shall be imposed upon any student except for cause as defined in the Manual and/or in the school rules and regulations as duly promulgated and only after due investigation shall have been conducted.”
Therefore, in effect, NU, by barring the enrollment of Guzman et al imposed sanction upon the students without due investigation – such act is illegal.
The Supreme Court also emphasized the minimum standards which must be met to satisfy the demands of procedural due process; and these are:
1. That the students must be informed in writing of the nature and cause of any accusation against them;
2. That they shall have the right to answer the charges against them, with the assistance of counsel, if desired;
3. That they shall be informed of the evidence against them;
4. That they shall have the right to adduce evidence in their own behalf; and
5. That the evidence must be duly considered by the investigating committee or official designated by the school authorities to hear and decide the case.