Saint Louis University, Inc. vs Baby Nellie Olairez et al.

written by Howard

G.R. No. 197126 – Political Law – Constitutional Law – The Judicial Department – Judicial Power – Judicial Review – Moot and Academic Issues

In September 2001, during the middle of the academic year, the College of Medicine of St. Louis University (SLU) imposed a new rule on its graduating medical students; that before they will be allowed to graduate, they must first pass a Comprehensive Written Exam (COWE), then two Oral Exams (these are different from the regular academic exams required by the school). The graduating med students (Baby Nellie Olairez et al.) took the COWE. When the results came out, none of them passed. Nevertheless, they already obtained prior permission from the university president for them to join the graduation rites to be held in April 2002. Meanwhile, they sought reconsideration of the results but SLU refused to give reconsideration. In March 2002, the med students filed a complaint against SLU to enjoin it from implementing its COWE rules.

While the case was pending, the med students were able to join the graduation rites; were able to attend and complete medical internship; and were able to obtain CHED recognition. But SLU refused to issue them their diploma, transcripts, and other credentials.

In June 2003, the trial court ruled in favor of Olairez et al. and SLU was directed to issue them their credentials. The trial court found that SLU arbitrarily changed the requirements for graduation in the middle of school year; The trial court reasoned that the graduating students of SLU College of Medicine have the right to expect that the requisites for graduation contained in their Student Handbook at the time they enrolled and started the school year should be maintained as that is a contract between those who enrolled and the school.

SLU did not agree with the decision. They appealed. The CA affirmed the trial court.

ISSUE: Whether or not the decision of the trial court must be reversed.

HELD: No. The issue has already become moot. There is no actual controversy anymore. A case or issue is considered moot and academic when it ceases to present a justiciable controversy by virtue of supervening events, so that an adjudication of the case or a declaration on the issue would be of no practical value or use. In such instance, there is no actual substantial relief which a petitioner would be entitled to, and which would be negated by the dismissal of the petition. Courts generally decline jurisdiction over such case or dismiss it on the ground of mootness.  Courts will not decide a case unless there is “a real and substantial controversy admitting of specific relief.”

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