Ateneo vs. CA 145 SCRA 100 (1986) G.R. No. L-56180, October 16, 1986


Fact: In a letter-complaint dated December 13, 1967 addressed to Rev. William Welsh S.J., Dean of Men, Dean of Resident Students, and Chairman of the Board of Discipline, College of Arts and Sciences, Ateneo de Manila, Carmelita Mateo, 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 committed on December 12, 1967 at about 5:15 in the evening at the Cervini Hall’s cafeteria. that Mr. Guanzon struck the complainant in the left temple. 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 Court stating 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 prominent and well known residents of Bacolod City, with the unceremonious expulsion of their son causing them actual, moral, and exemplary damages as well as attorney’s fees. After due trial, the lower court found for the Guanzons and ordered the university to pay them P92.00 as actual damages; P50,000.00 as moral damages; P5,000.00 as attorney’s fees and to pay the costs of the suit. 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.

Issue: Whether the petitioner deprived the respondent due process in the administrative proceeding?

Held: No,  the respondent was accorded administrative due process in his dismissal cases according to the minimum standards laid down by the Court to meet the demands of procedural due process are:

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

(2) they shall 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.

When the letter-complaint was read to respondent, he admitted the altercation with the waitress and his slapping her on the face. petitioner did not stop with the admission. The Board of Discipline was made up of distinguished members of the faculty and there is nothing in the records to cast any doubt on their competence and impartiality insofar as this disciplinary investigation is concerned. respondent himself appeared before the Board of Discipline. He admitted incident, then begged to be excused so he could catch the boat for Bacolod City. Juan Ramon, therefore, was given notice of the proceedings; he actually appeared to present his side; the investigating board acted fairly and objectively; and all requisites of administrative due process were met.


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