ADMU vs Capulong

Facts: Leonardo H. Villa, a first year law student of Petitioner University, died of serious physical
injuries at Chinese General Hospital after the initiation rites of !uila Le"is. #ienvenido $ar!ue%
was also hospitali%ed at the Capitol $edical Center for acute renal failure occasioned &y the
serious physical injuries inflicted upon hi' on the sa'e occasion. Petitioner (ean Cynthia del
Castillo created a )oint d'inistration*Faculty*+tudent ,nvesti"atin" Co''ittee which was
tas-ed to investi"ate and su&'it a report within ./ hours on the circu'stances surroundin" the
death of Lennie Villa. +aid notice also re!uired respondent students to su&'it their written
state'ents within twenty*four 0/12 hours fro' receipt. lthou"h respondent students received a
copy of the written notice, they failed to file a reply. ,n the 'eanti'e, they were placed on
preventive suspension. 3he )oint d'inistration*Faculty*+tudent ,nvesti"atin" Co''ittee, after
receivin" the written state'ents and hearin" the testi'onies of several witness, found a pri'a
facie case a"ainst respondent students for violation of 4ule 5 of the Law +chool Catalo"ue
entitled 6(iscipline.6 4espondent students were then re!uired to file their written answers to the
for'al char"e. Petitioner (ean created a (isciplinary #oard to hear the char"es a"ainst
respondent students. 3he #oard found respondent students "uilty of violatin" 4ule 7o. 5 of the
teneo Law +chool 4ules on (iscipline which prohi&its participation in ha%in" activities.
However, in view of the lac- of unani'ity a'on" the 'e'&ers of the #oard on the penalty of
dis'issal, the #oard left the i'position of the penalty to the University d'inistration.
ccordin"ly, Fr. #ernas i'posed the penalty of dis'issal on all respondent students.
4espondent students filed with 43C $a-ati a 348 since they are currently enrolled. 3his was
"ranted. 348 was also issued enjoinin" petitioners fro' dis'issin" the respondents. day
after the e9piration of the te'porary restrainin" order, (ean del Castillo created a +pecial #oard
to investi"ate the char"es of ha%in" a"ainst respondent students &as and $endo%a. 3his was
re!uested to &e stric-en out &y the respondents and ar"ued that the creation of the +pecial
#oard was totally unrelated to the ori"inal petition which alle"ed lac- of due process. 3his was
"ranted and reinstate'ent of the students was ordered.
,ssue: :as there denial of due process a"ainst the respondent students.
Held: 3here was no denial of due process, 'ore particularly procedural due process. (ean of
the teneo Law +chool, notified and re!uired respondent students to su&'it their written
state'ent on the incident. ,nstead of filin" a reply, respondent students re!uested throu"h their
counsel, copies of the char"es. 3he nature and cause of the accusation were ade!uately
spelled out in petitioners; notices. Present is the twin ele'ents of notice and hearin".
4espondent students ar"ue that petitioners are not in a position to file the instant petition under
4ule <= considerin" that they failed to file a 'otion for reconsideration first &efore the trial court,
there&y &y passin" the latter and the Court of ppeals. ,t is accepted le"al doctrine that an
e9ception to the doctrine of e9haustion of re'edies is when the case involves a !uestion of law,
as in this case, where the issue is whether or not respondent students have &een afforded
procedural due process prior to their dis'issal fro' Petitioner University.
$ini'u' standards to &e satisfied in the i'position of disciplinary sanctions in acade'ic
institutions, such as petitioner university herein, thus:
0>2 the students 'ust &e infor'ed in writin" of the nature and cause of any accusation a"ainst
the'?
0/2 that they shall have the ri"ht to answer the char"es a"ainst the' with the assistance of
counsel, if desired:
052 they shall &e infor'ed of the evidence a"ainst the'
012 they shall have the ri"ht to adduce evidence in their own &ehalf? and
0=2 the evidence 'ust &e duly considered &y the investi"atin" co''ittee or official desi"nated
&y the school authorities to hear and
:H@4@F84@, the instant petition is G473@(? the order of respondent )ud"e dated $ay >.,
>AA> reinstatin" respondents students into petitioner university is here&y 4@V@4+@(. 3he
resolution of petitioner )oa!uin #ernas +. )., then President of teneo de $anila University
dated $arch >AA>, is 4@,7+33@( and the decision of the +pecial #oard (,+$,++,7G
respondent students (@L #+ and B8+,$8 $@7(8B dated $ay /C, >AA> is here&y
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