1

The Anti-Bullying Act of 2013:

Schools Jurisdiction on Bullying Acts Outside Its Premises
Syed Kamal Reza L. Ampatuan, Arnel Benedict T. Degara, Regina Via G. Garcia,
Lourdes Jane N. Mahipus*

ABSTRACT
The bullying acts committed by students have been rapidly rampant in schools
from various places within our society. The Kowalski case highlights the
implementation of punishment by the school of an act committed by the student
outside the school premises. These bullying acts were done beyond the ambit of
the schools jurisdiction through the use of the internet and in the verge of
cyberspace. Despite court attempts and efforts to hold over cases involving the
bullying acts committed by these students outside school premises, the schools
prerogative to impose disciplinary action and sanction still prevails and remains
as the first one to hear over cases regarding harassment and bullying commenced
outside the school campus. The question here lies as to what extent does the
schools jurisdiction granted by Philippine law have in trying to prevent bullying
and how extensive the jurisdiction of schools are given when it comes to bullying
acts done outside school premises by electronic means or cyber-bullying.


1. Questions
Last September 12, 2013, President Benigno Aquino the third has recently signed into
law the Anti-Bullying act which serves to protect school students from abuses made by their
fellow classmates. Under Section 3 of the Anti-Bullying Act of 2013
1
:
The Law intended to suppress, minimize, or eradicate
bullying in schools by directing primary and secondary schools
to adopt policies to address the existence of bullying in their
respective institutions.
The constitution mandates all educational institutions to strengthen ethical and spiritual
values, develop moral character and personal discipline.
2
This law is somewhat, a step taken by
congress to put into action the principle inlaid in the constitution that mandates all educational
institutions to develop moral character and personal discipline. By defining bullying and
mandating all schools to curb such actions, the law is a step forward in further strengthening the
policy of the state in developing moral character and personal discipline among the youth.

* Legal Writing Students of LLB 1- Viada, College of Law, Ateneo de Davao University

1
Republic Act No. 10627 Anti-Bullying Act (2013)

2
1987 Constitution of the Philippines Article XIV Section 3 (2)
2

The law directs schools to prohibit acts such as bullying inside and outside school if the
acts create a hostile environment for the child in school. It also prohibits any retaliation made
towards the person who reports bullying and establishes strategies in addressing bullying such as
reporting acts of bullying, its investigation, protection of the person who reports the acts from
retaliation, counseling towards the victim, perpetrators, and appropriate family members,
enabling anonymous reporting, and education of parents and guardians about the nature of
bullying, amongst others. The law then provides for sanctions to administrators and schools who
shall fail to comply with the requirements under the act. Clearly, the law intends to stop bullying
in schools, by requiring schools to follow the requirements provided by the law, and sanctioning
those schools and their administrators for non-compliance.
One of the most interesting features of the law is its inclusion of cyber-bullying
3
. Thus,
the law grants schools jurisdiction over cyber-bullying. This is an important innovation since
bullying these days, with its many forms, can now be done through electronic means, such as
social networking websites. As later discussed in the case of Kowalski, this form of bullying has a
very strong impact upon the lives of young students.

The questions to be addressed then are the following:

1. What extent does the schools jurisdiction have in trying to prevent bullying?
2. How much is the extent of jurisdiction given to schools when it comes to bullying
done through electronic means or cyber-bullying?
Different cases from other countries as well as from the Philippines that pertain to the
issue of bullying will be discussed as well as the Philippine laws that help in answering these
questions. Thus, it will be examined how a controversial issue, such as bullying, impacts the lives
of different people. Furthermore, this paper will look into where the Philippine laws are lacking
compared to Anti-Bullying laws of other countries, as a well as to the reality of bullying and how
the law is too limited when it comes to addressing the issue.

2. Kowalski
Kowalski was a case filed in the United States Court of Appeals. The petitioner was Kara
Kowalski, a student of Berkeley County School District, who created and administered a
myspace.com interactive discussion group page, entitled Students against Shays Herpes or
S.A.S.H., directed towards a classmate. The discussion group page was created at home, on her
home computer, after school hours. The group was used by Kowalski to encourage her classmates
to participate in offensive conversations about one of their classmates. The discussion involved
Kowalskis classmates who posted defamatory and offensive statements and photo shopped
pictures of the targeted student.
The parents of the victim filed a harassment complaint with the school upon their
discovery of the MySpace page. The school and district took the necessary precautions to
investigate the complaint, including interview of Kowalski who admitted to creating the group
and page. The schools principal, together with the school board, determined discipline against

3
Anti-Bullying Act of 2013 Section 2 (d) provides:

Cyber-bullying or any bullying done through the use of technology or any electronic means.

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Kowalski was appropriate because she had created a hate website in violation of school policy
and the Student Code of Conduct (CoC) against harassment, bullying, and intimidation.
4

Afterward, Kowalski filed a suit alleging that the school district violated her
first amendment right of free speech, and violation of due process, violations of corresponding
state laws, and a claim of intentional infliction of emotional distress. Additionally Kowalski
sought a declaratory judgment that the School Districts harassment policy was unconstitutionally
vague or overbroad and an injunction requiring the school to expunge any record of her
discipline.
5

The issue before the United States Court of Appeals was whether or not the first
amendment permits a public school to discipline a student for speech that occurs off-campus and
not at a school-sponsored event, and that is not directed at the school.
The court argued that the law states that a students first amendment rights are not as
extensive as an adult
6
, and that public schools have a compelling interest in regulating speech
that interferes with or disrupts the work and discipline of the school, including discipline for
student harassment and bullying
7
and that schools have a duty to protect their students from
harassment and bullying in the school environment
8
.
When the petitioner argued that the school districts punishment violated her first
amendment rights
9
as her speech took place at home, after school hours, on her home computer
and therefore was not within the purview of the schools right to discipline, the court disagreed.
When the internet is used as the medium, the court found a sufficient connection between
Kowalskis speech and the schools interest in the order, safety and well-being of its students to
justify the schools regulation of the speech.
The court followed the following factors to come up with the connection
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:
1. Kowalski knew that the actions taken in her home could reasonably be expected to
reach the school or impact the school environment;
2. It was foreseeable that the speech would reach the school;
3. That the dialogue would and did take place among Musselman High School students;
4. That fall out from her conduct and speech would be felt in the school itself;

4
No. 10-1098 (2011)

5
No. 10-1098 (2011)

6
Tinker v. des Moines Indep. Community Sch. Dist. 393 US 503 (1969)

7
No. 10-1098 (2011)

8
No. 10-1098 (2011)

9
The First Amendment of the United States of America provides:

Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise
thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to
assemble, and to petition the government for a redress of grievances.

10
http://www.scribproquo.com/2012/01/23/case-summary-the-queen-of-charm-loses-her-appeal-kowalski-
v-berkeley-county-schools/
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5. That the groups name included the word Students;
6. That it was verbally anticipated that the targeted student would see the page;
7. That a vast majority of the group was Musselman High School students, invited by
Kowalski.

The court concluded that a school/school board has a compelling interest in regulating
student speech that interferes with or disrupts the work and discipline of the school, including
discipline for student harassment and bullying and that schools have a duty to protect their
students from harassment and bullying in the school environment that outweighs a students
rights of free speech, even when exercised away from school.

3. Case Law
In the case of De La Salle University, Inc. v. Court of Appeals,
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it presents a
situation where an attack against a student outside the premises of the school.
Mr. James Yap went out of the campus using the Engineering Gate to buy candies across
Taft Avenue. As he was about to re-cross Taft Avenue, he heard heavy footsteps at his back.
Eight to ten guys were running towards him. He panicked. He did not know what to do. Then,
respondent Bungubung punched him in the head with something heavy in his hands "parang
knuckles."
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Respondents Reverente and Lee were behind Yap, punching him. Respondents
Bungubung and Valdes who were in front of him, were also punching him. As he was lying on
the street, respondent Aguilar kicked him. People shouted; guards arrived; and the group of
attackers left. Yap later filed a complaint for direct assault to the Discipline Board against his
attackers. De La Salle University later on punished its students who were the attackers of Yap.

As stated in the case, the school has an interest in teaching the student, discipline, a
necessary, if not indispensible, value in any field of learning. By instilling discipline, the school
teaches discipline. Accordingly, the right to discipline the student likewise finds basis in the
freedom of what to teach.
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Therefore, it is within the bounds of the school to sanction their students for unacceptable
acts committed outside its premises. This punishment is a form of disciplinary action that helps
their student learn their lesson in causing harm to another person.


4. Conundrum

The doctrine in Kowalski, being a foreign case, is inapplicable in Philippine jurisdiction.
But it presents the extent of jurisdiction that should be given to schools when it comes to cyber-
bullying. The case lets us compare our laws to the jurisprudence laid in the Kowalski. It boils
down to the following questions:


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G.R. No. 127980

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G.R. No. 127980

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G.R. No. 127980
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1. How much is the actual jurisdiction given by the anti-bullying law and other existing
laws to schools when it comes to bullying?
2. How much jurisdiction is extended to schools by the anti-bullying act when it comes
to cyber-bullying?
As it has been indicated, it is a principle inlaid in the 1987 Philippine Constitution that all
educational institutions must take steps to strengthen ethical and spiritual values, develop moral
character and personal discipline. In its duty to discipline students, schools, in Angeles vs. Hon.
Sison
14
it was held by the Supreme Court that:
A school has the right to investigate, suspend, and/or
expel a student for a misconduct committed outside the school
premises and beyond school hours if it affects the morale of the
school and if it is adverse to the schools order and the students
welfare and advancement.
This case shows us that the school has jurisdiction over acts committed by the students
outside the school premises. This principle is somewhat similar to section 3 (a) (2) of the Anti-
Bullying Act of 2013.
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This provision of the Anti-Bullying Act of 2013 can be compared in the doctrine laid in
the Kowalski when it held that schools have compelling interest when it comes to acts of bullying
made through the internet that affects order, safety and well-being of students in school and that
the school has compelling interest in regulating student speech that interferes with or disrupts the
work and discipline of the school. Clearly, Not only does the new law give jurisdiction in
prohibiting bullying outside school but also through the use of technology or electronic devise not
owned by the school, with the requisite that such acts must create a hostile environment for the
victim, infringe his or her rights at school and materially or substantially disrupt his education
process.

5. Challenge
The New Jersey Anti-Bullying Bill of Rights Act, also known as P.L. 2010, Chapter 122,
is a policy created in 2011 by New Jersey legislature to combat bullying in public schools
throughout the state. This act is an extension of the states original anti-bullying law, which was
first enacted in 2002.
Both the New Jersey House of Representatives and the Senate passed the law
unanimously in November 2010 and Governor Chris Christie signed the bill on January 5, 2011.
The law began to take effect at the beginning of the 2011 school year. Along with both
Democratic and Republican legislators, organizations such as Garden State Equality, the Anti-

14
112 SCRA 26
15
The Anti-Bullying Act of 2013 Section 3 (a) (2) provides:

Where the school is given jurisdiction in prohibiting Bullying at a location, activity, function or
program that is not school related and through the use of technology or an electronic device that is not
owned, leased or used by a school if the act or acts in question create a hostile environment at school for
the victim, infringe on the rights of the victim at school, or materially and substantially disrupt the
education process or the orderly operation of a school.

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Defamation League of New Jersey
16
, and the New Jersey Coalition for Bullying Awareness and
Prevention
17
worked on creating this policy. The Anti-Bullying Bill of Rights provides a strong
and thorough definition of bullying. The new bills definition not only describes bullying as a
harmful action towards another student, but as any act that infringes on a students rights at
school.
Congress of New Jersey adopted a definition of school leader and penalty for a student
when he commits an act of bullying inside their campus.
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Any pupil who is guilty of continued
and willful disobedience, or of open defiance of the authority of any teacher or person having
authority over him, or of the habitual use of profanity or of obscene language, or who shall
cut, deface or otherwise injure any school property, shall be liable to punishment and to
suspension or expulsion from school.
Conduct which shall constitute good cause for suspension or expulsion of a pupil
guilty of such conduct shall include, but not be limited to, any of the following:

1. Continued and willful disobedience;
2. Open defiance of the authority of any teacher or person, having authority over
him;
3. Conduct of such character as to constitute a continuing danger to the physical
well- being of other pupils;
4. Physical assault upon another pupil;
5. Taking, or attempting to take, personal property or money from another pupil, or
from his presence, by means of force or fear;
6. Willfully causing, or attempting to cause, substantial damage to school property;
7. Participation in an unauthorized occupancy by any group of pupils or others of
any part of any school or other building owned by any school district, and failure
to leave such school or other facility promptly after having been directed to do so
by the principal or other person then in charge of such building or facility;
8. Incitement which is intended to and does result in unauthorized occupation by
any group of pupils or others of any part of a school or other facility owned by
any school district;
9. Incitement which is intended to and does result in truancy by other pupils;
10. Knowing possession or knowing consumption without legal authority of alcoholic
beverages or controlled dangerous substances on school premises, or being under
the influence of intoxicating liquor or controlled dangerous substances while on
school premises.
11. Harassment, intimidation, or bullying.

16
http://newjersey.adl.org/

17
http://www.njbullying.org/

18
The New Jersey Anti-Bullying Bill of Rights Act Section 13 provides:

As used in this section, "school leader" means a school district staff member who holds a position that
requires the possession of a chief school administrator, principal, or supervisor endorsement. A school
leader shall complete training on issues of school ethics, school law, and school governance as part of
the professional development for school leaders required pursuant to State Board of Education
regulations. Information on the prevention of harassment, intimidation, and bullying shall also be
included in the training. The training shall be offered through a collaborative training model as
identified by the Commissioner of Education, in consultation with the State Advisory Committee on
Professional Development for School Leaders.
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In the Philippines, the Congress enacted The Anti-Bullying Act of 2013. It became a
policy to protect the children who are in elementary and high school level against being bullied
by their classmates and schoolmates. The benefits to students are significant as well. When
children know that the school they attend actively works to make the learning environment a safe
environment, and that bullying is not tolerated, they can let their guard down and focus their
attention on learning rather than staying safe. Even students who are not victims or bullies but
have witnessed bullying, feel more comfortable and secure knowing that the school community,
students, staff and administration stand together against bullying.
Congress adopted a definition of acts of bullying, who are liable for the such acts
committed by the child. Thus, pertinent sections of the law provide:
Section 2. Acts of Bullying. For purposes of this Act,
bullying shall refer to any severe or repeated use by one or
more students of a written, verbal or electronic expression, or a
physical act or gesture, or any combination thereof, directed at
another student that has the effect of actually causing or placing
the latter in reasonable fear of physical or emotional harm or
damage to his property; creating a hostile environment at school
for the other student; infringing on the rights of the other student
at school; or materially and substantially disrupting the education
process or the orderly operation of a school; such as, but not
limited to, the following:
(a) Any unwanted physical contact between the bully and the
victim like punching, pushing, shoving, kicking, slapping,
tickling, headlocks, inflicting school pranks, teasing, fighting
and the use of available objects as weapons;
(b) Any act that causes damage to a victims psyche and/or
emotional well-being;
(c) Any slanderous statement or accusation that causes the
victim undue emotional distress like directing foul language
or profanity at the target, name-calling, tormenting and
commenting negatively on victims looks, clothes and body;
and
(d) Cyber-bullying or any bullying done through the use of
technology or any electronic means.
Section 3. Adoption of Anti-Bullying Policies. All
elementary and secondary schools are hereby directed to adopt
policies to address the existence of bullying in their respective
institutions. Such policies shall be regularly updated and, at a
minimum, shall include provisions which prohibit the following
acts:
A. Prohibit the following acts
1. Bullying on school grounds; property immediately
adjacent to school grounds; at school-sponsored or school-
related activities, functions or programs whether on or off school
grounds; at school bus stops; on school buses or other vehicles
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owned, leased or used by a school; or through the use of
technology or an electronic device owned, leased or used by a
school;
2. Bullying at a location, activity, function or program
that is not school related and through the use of technology or an
electronic device that is not owned, leased or used by a school if
the act or acts in question create a hostile environment at school
for the victim, infringe on the rights of the victim at school, or
materially and substantially disrupt the education process or the
orderly operation of a school; and
3. Retaliation against a person who reports bullying, who
provides information during an investigation of bullying, or who
is a witness to or has reliable information about bullying.
As explained earlier about who will be liable for the bullying acts committed by the
student inside the school, it is clear that the school should be liable because the child is under
their supervision as stated in Article 218
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and 219
20
or the Family Code of the Philippines.
The gist of the argument rises on the issue whether or not the school shall be liable for the
bullying acts committed by the student outside the premises of the school because it is known that
the bullying act was done beyond the premises of the school.
Even though the behavior may have taken place away from school, it could be have an
impact on campus. So what course of action can the school officials do? Should they ignore the
behavior, discipline the students involved, or look for an alternative way to deal with the
problem? The answer isnt obvious.
To simplify these two rulings, it could be said that schools must not punish political
expression as long as it doesnt lead to disruption, but they can impose sanctions against certain
types of lewd speech that go beyond the boundaries of socially appropriate behavior. Based on
the ruling, it would seem pretty obvious that schools have the rightsome would say
responsibilityto intervene in cases of harassment or cyber-bullying but, the case law refers to
activities that took place in campus. These landmark cases were decided long before students

19
Art. 218 of the Family Code of the Philippines provides:

The school, its administrators and teachers, or the individual, entity or institution engaged in child are
shall have special parental authority and responsibility over the minor child while under their
supervision, instruction or custody. Authority and responsibility shall apply to all authorized activities
whether inside or outside the premises of the school, entity or institution. (349a)

20
Art. 219 of the Family Code of the Philippines provides:

Those given the authority and responsibility under the preceding Article shall be principally and
solidarily liable for damages caused by the acts or omissions of the unemancipated minor. The parents,
judicial guardians or the persons exercising substitute parental authority over said minor shall be
subsidiary liable. The respective liabilities of those referred to in the preceding paragraph shall not
apply if it is proved that they exercised the proper diligence required under the particular circumstances.

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started using cell phones and internet browsers that allow them to have an easier medium to
conduct such acts.

6. Constriction
The Supreme Court of United States decided Kowalski that the school has the right to
impose penalties when their student committed harassment and bullying acts even though it was
outside their premises.
However, there are two cases that have an implication on the actions done by the school
to sanction a penalty to their students when their acts of harassment and bullying were committed
outside the school.
A.
The first case that presents a contradiction is De la Salle University Inc. v. Court of
Appeals
21
.
On March 30, 1995, petitioner, Yap, filed a complaint with the Discipline Board of
DLSU charging private respondents with direct assault. Later on, the DLSU-CSB Joint Discipline
Board issued a Resolution finding private respondents guilty. They were meted the supreme
penalty of automatic expulsion.
Here, the Supreme Court reversed the decision of the school because the right of due
process of the respondents was violated. The Court said:
It is true that schools have the power to instill discipline in their
students as subsumed in their academic freedom and that "the
establishment of rules governing university-student relations,
particularly those pertaining to student discipline, may be
regarded as vital, not merely to the smooth and efficient
operation of the institution, but to its very survival."94 This
power, however, does not give them the untrammelled discretion
to impose a penalty which is not commensurate with the gravity
of the misdeed. If the concept of proportionality between the
offense committed and the sanction imposed is not followed, an
element of arbitrariness intrudes. That would give rise to a due
process question.
We agree with respondent CHED that under the circumstances,
the penalty of expulsion is grossly disproportionate to the gravity
of the acts committed by private respondents Bungubung,
Reverente, and Valdes, Jr. Each of the two mauling incidents
lasted only for few seconds and the victims did not suffer any
serious injury. Disciplinary measures especially where they
involve suspension, dismissal or expulsion, cut significantly into
the future of a student. They attach to him for life and become a
mortgage of his future, hardly redeemable in certain cases.
Officials of colleges and universities must be anxious to protect

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G.R. No. 127980
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it, conscious of the fact that, appropriately construed, a
disciplinary action should be treated as an educational tool rather
than a punitive measure.
The Supreme Court here pointed out that the school cannot impose penalty to their
students without proper due process as what Article III Section I of the Constitution stated No
person shall be deprived of life, liberty, or property without due process of law, nor shall any
person be denied the equal protection of the laws.
A formal trial-type hearing is not, at all times and in all instances, essential to due process
it is enough that the parties are given a fair and reasonable opportunity to explain their respective
sides of the controversy and to present supporting evidence on which a fair decision can be based.
"To be heard" does not only mean presentation of testimonial evidence in court one may also be
heard through pleadings and where the opportunity to be heard through pleadings is accorded,
there is no denial of due process.
B.
The second case is Gendelman v. Glenbrook North High School.
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In one Sunday of May
2003, more than 50 students from Glenbrook North High School in Illinois participated in a
powder-puff football game at a local forest preserve. At the conclusion of the game, the senior
girls held a hazing ritual of the junior girls that included significant violence. Senior girls
punched, kicked, hit, and smeared paint and excrement on the junior girls. Some of the junior
girls injuries required medical treatment. The district responded by starting suspension and
expulsion proceedings s against the senior girls. Most students suspended were seniors who were
set to graduate in a few weeks. Two such seniors brought an action in the federal court to enjoin
the school district from preventing their graduations. The Northern District of Illinois denied their
request for the temporary restraining order. Parenthetically, the discipline was based on a little
known school district prohibition against "secret societies" even though everyone in the school,
for many years, knew of the event.
According to the Court in this case, Courts generally hold that a students interest in
extracurricular activities is not constitutionally protected because participation is a privilege to
which no property or liberty interest attaches. Accordingly, schools have greater discretion to
impose disciplinary consequences to participants in extracurricular activities whose offending
conduct occurs off campus.
In the case of De La Salle University Inc. v. Court of Appeals,
23
the Court reversed the
decision and the penalty imposed by the school to the respondents because according to the Court
the school made a violation on the proper due process. However, In the case of Gendelman v.
Glenbrook North High School
24
the Court affirm on the decision made by the school to suspend
and expel the students who are guilty of harassment and bullying even though off the campus
because schools have the right to discipline their students and such penalty imposed is an act of
disciplining there students for the acts of harassment and bullying done by their students. Schools
have a greater jurisdiction over their students than the courts.

22
LEXIS 8508 (N.D. III. May 21, 2003)

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G.R. No. 127980

24
LEXIS 8508 (N.D. III. May 21, 2003)
11

The second case has a similarity in the case of Kowalski in terms of the decision made by
the Supreme Court of the United States, where in the Court concur to the disciplinary actions
made by the school to the respondent. According to latter, the school district violated her
first amendment right of free speech, and violation of due process. The Court concluded that a
school has the jurisdiction in regulating student speech that disrupts the policy of the school,
including discipline for student harassment and bullying and that schools have a duty to protect
their students from harassment and bullying in the school environment that outweighs a students
rights of free speech, even when exercised away from school.

7. Conclusion
The school has jurisdiction over cases involving the bullying acts committed by the
students outside school premises and has the power and authority to impose disciplinary measures
granted by the Anti-bullying Act. The outside jurisdiction emphasized here involves the
cyberspace and speaks of the internet use. Furthermore, jurisdiction means prevention and
discipline. The schools ambit of discipline extends to cyber-bullying through computers
regardless of the schools ownership and control over the computers. The courts have no
jurisdiction unless on administrative matters and if it so happens that the school commits grave
abuse of discretion in implementing the policies required by the anti-bullying act, or non-
compliance thereof, such matters could result in administrative actions to be filed or complained
before the proper authorities such as the Department of Education or the courts.
In the of De La Salle University Inc. v. Court of Appeals,
25
the court said that the under
the Bill of rights, the school violated due process, however, in the string of cases regarding this
matter, the court ruled that the school has the jurisdiction over cases regarding harassment and
bullying done even outside the school. Consequently, the school possesses the jurisdiction over
the students who committed the bullying acts outside school premises since the school has a
significant role in exercising authority and discipline and because students are the persons
concerned.











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G.R. No. 127980
12

REFERENCES

Bernas, J. G. (2009). The 1987 Constitution of the Republic of the Philippines: A Commentary.
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Hanks, J. C. (2004). School Violence: From Discipline to Due Process. Chicago: American Bar
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Kowalski v. Berkley County Schools II. Digest. (2011). Retrieved from
http://caselaw.findlaw.com/us-4th-circuit/1575495.html
Legal Information Institute. (2013). First Amendment. Retrieved from
http://www.law.cornell.edu/constitution/first_amendment
The New Jersey Anti-Bullying Bill of Rights Act. (2011). Retrieved from
http://www.njleg.state.nj.us/2010/Bills/AL10/122_.PDF
Official Gazette. (2013). The Anti-Bullying Act of 2013. Retrieved from
http://www.gov.ph/2013/09/12/republic-act-no-10627/
Pineda, E. L. (2011). The Family Code of the Philippines Annotated. Quezon City: Central Books
Supply, Inc.