Tuesday, March 06, 2012

Ateneo de Manila University vs. CA [G.R. No. L-56180 October 16, 1986]

Facts: A waitress in the cafeteria of Cervini Hall inside the university campus charged Juan Ramon Guanzon, son of private respondents Romeo Guanzon and Teresita Regalado, and a boarder and first year student of the university with unbecoming conduct for striking her at her left temple. The incident came about when Juan Guanzon was asking for siopao at the counter, however he was asked to wait which made him madder. 

The university conducted an investigation of the slapping incident. On the basis of the investigation results, Juan Ramon was dismissed from the university.The dismissal of Juan Ramon triggered off the filing of a complaint for damages by his parents against the university in the then Court of First Instance of Negros Occidental at Bacolod City. The complaint states that Juan Ramon was expelled from school without giving him a fair trial in violation of his right to due process and that they are entitled to actual, moral, and exemplary damages as well as attorney's fees. 

In its answer, the university denied the material allegations of the complaint and justified the dismissal of Juan Ramon on the ground that his unbecoming behavior is contrary to good morals, proper decorum, and civility, that such behavior subjected him as a student to the university's disciplinary regulations' action and sanction and that the university has the sole prerogative and authority at any time to drop from the school a student found to be undesirable in order to preserve and maintain its integrity and discipline so indispensable for its existence as an institution of learning. 

After due trial, the lower court found for the Guanzons. Upon appeal to the Court of Appeals by the university, the trial court's decision was initially reversed and set aside. The complaint was dismissed. However, upon motion for reconsideration filed by the Guanzons, the appellate court reversed its decision and set it aside through a special division of five. In the resolution issued by the appellate court, the lower court's decision was reinstated. The motion for reconsideration had to be referred to a special division of five in view of the failure to reach unanimity on the resolution of the motion, the vote of the regular division having become 2 to 1.The petitioner now asks us to review and reverse the resolution of the division of five. 

Issue: Whether or not the Supreme Court may decline to review the said Board’s findings 

Held: Yes. By reason of their special knowledge and expertise gained from the handling of specific matters falling under their respective jurisdictions, we ordinarily accord respect if not finality to factual findings of administrative tribunals. However, there are exceptions to this rule and judicial power asserts itself whenever the factual findings are not supported by evidence; where the findings are vitiated by fraud, imposition, or collusion; where the procedure which led to the factual findings is irregular; when palpable errors are committed; or when a grave abuse of discretion, arbitrariness, or capriciousness is manifest. 

The Board of Discipline was made up of distinguished members of the faculty-Fr. Francisco Perez, Biology Department Chairman; Dr. Amando Capawan, a Chemistry professor; Assistant Dean Piccio of the College; and Dr. Reyes of the same College. There is nothing in the records to cast any doubt on their competence and impartiality insofar as this disciplinary investigation is concerned. 

Moreover, notwithstanding the non-participation of the private respondents, the university, as stated earlier, undertook a fair and objective investigation of the slapping incident. 

Due process in administrative proceedings also requires consideration of the evidence presented and the existence of evidence to support the decision. 

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