Case Digest: Guzman vs. National University; 142 SCRA 706 (1986)

             Due Process | Constitutional Law

Facts:

Diosdado Guzman, Ulysses Urbiztondo, and Ariel Ramacula, students of the National University, filed a petition seeking relief from the school's refusal to allow them to enroll. The students claimed that the university denied their enrollment based on their participation in peaceful mass actions within the campus. They argued that this was a continuation of the university's disregard for students' constitutional rights and due process, as previously established in a related case. The students contended that they were expelled without cause or proper notification. 

The university countered by stating that the students' failure to enroll was their own fault and not related to their exercise of rights. They also provided specific reasons for the individual students' exclusion, such as poor academic performance and involvement in disruptive activities without permission. The university maintained that the students' enrollment privileges had been forfeited and that their enrollment was not in the best interest of all parties involved. 

However, the court issued a mandatory injunction, ordering the university to allow the students to enroll in the coming semester while disciplinary proceedings against them could continue. The court also stated that Guzman, despite facing criminal charges, should be allowed to resume his studies for the time being, as his father assured lawful and peaceful resolution of any grievances.

In their reply, the students denied the university's claims and stated that their attempts to enroll were repeatedly rejected, even when no disciplinary charges were pending against them. 

Issue:
WoN the university denied the students' constitutional right.

 

Held: 

Immediately apparent from a reading of respondents' comment and memorandum is the fact that they had never conducted proceedings of any sort to determine whether or not petitioners-students had indeed led or participated "in activities within the university premises, conducted without prior permit from school authorities, that disturbed or disrupted classes therein"  or perpetrated acts of "vandalism, coercion and intimidation, slander, noise barrage and other acts showing disdain for and defiance of University authority." 

Parenthetically, the pendency of a civil case for damages and a criminal case for malicious mischief against petitioner Guzman, cannot, without more, furnish sufficient warrant for his expulsion or debarment from re-enrollment. Also apparent is the omission of respondents to cite this Court to any duly published rule of theirs by which students may be expelled or refused re-enrollment for poor scholastic standing.

Under the Education Act of 1982, the petitioners, 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."

Petitioners were being denied this right, or being disciplined, without due process, in violation of the admonition in the Manual of Regulations for Private Schools that "(n)o 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." 

This Court is therefore constrained, as in Berina v. Philippine Maritime Institute, to declare illegal this act of respondents of imposing sanctions on students without due investigation.

Principle:

There are withal minimum standards which must be met to satisfy the demands of procedural due process; and these are, that 

(1) the students must be informed in writing of the nature and cause of any accusation against them; 

(2) they shag have the right to answer the charges against them, with the assistance of counsel, if desired; 

(3) they shall be informed of the evidence against them; 

(4) they shall have the right to adduce evidence in their own behalf; and

(5) the evidence must be duly considered by the investigating committee or official designated by the school authorities to hear and decide the case.