Alcuaz v. PSBA [GR 76353, 2 May 1988] Second division, Paras (J): 3 concur.

Facts: Sophia Alcuaz, Ma. Cecilia Alindayu, Bernadette Ang, Irna Anonas, Ma. Remedios Baltazar,
Corazon Bundoc, John Carmona, Anna Shiela Dinoso, Rafael Encarnacion, et. al., are all bonafide
students of the Philippine School of Business Administration (PSBA) Quezon City. As early as 22
March 1986, the students and the PSBA, Q.C. had already agreed on certain matters which would
govern their activities within the school. In spite of the agreement, the students felt the need to
hold dialogues. Among others they demanded the negotiation of a new agreement, which demand
was turned down by the school, resulting in mass assemblies and barricades of school entrances.
Subsequently dialogues proved futile. Finally, on 8 October 1996, the students received uniform
letters from PSBA giving them 3 days to explain why the school should not take/mete out any
administrative sanction on their direct participation and/or conspiring with others in the commission
of tumultuous and anarchic acts on October 2, 3, and 7. On 22 October 1982, the letter was
answered by the counsel for the students in a reply letter. During the regular enrollment period, the
students were allegedly blacklisted and denied admission for the second semester of SY 1986-1987.
On 28 October 1986 the President of the Student Council filed a complaint with the Director of the
Ministry of Education, Culture and Sports (MECS) against the PSBA for barring the enrollment of the
Student Council Officers and student leaders. Simultaneously on the same date, the student council
wrote the President, Board of Trustees, requesting for a written statement of the schools final
decision regarding their enrollment. Another demand letter was made by Counsel for the students
Atty. Alan Romullo Yap, also to the President, Board of Trustees, to enroll his clients within 48 hours.
All these notwithstanding, no relief appeared to be forthcoming. The students filed a petition for
review on certiorari and prohibition with preliminary mandatory injunction.

Issue: Whether the students were deprived of due process in the refusal of PSBA to readmit them.

Held: After the close of the first semester, the PSBA-QC no longer has any existing contract either
with the students or with the intervening teachers. The contract having been terminated, there is
no more contract to speak of. The school cannot be compelled to enter into another contract with
said students and teachers. The right of the school to refuse re-enrollment of students for academic
delinquency and violation of disciplinary regulations has always been recognized by the Court, as it
is sanctioned by law. Section 107 of the Manual of Regulations for Private Schools considers
academic delinquency and violation of disciplinary regulations as valid grounds for refusing re-
enrollment of students. Due process in disciplinary cases involving students does not entail
proceedings and hearings similar to those prescribed for actions and proceedings in courts of
justice. Such proceedings may be summary and cross-examination is not even an essential part
thereof. Accordingly, 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. Herein, conditions 3, 4 and 5 had not been complied with. The Court, however,
ordered an investigation to be conducted by the school authorities in the interest of justice. Further,
it is well settled that by reason of their special knowledge and expertise gained from the handling of
specific matters falling under their respective jurisdictions, the Court ordinarily accords respect if
not finality to factual findings of administrative tribunals, unless 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. Herein, a careful
scrutiny of the Report and Recommendation of the Special Investigating Committee shows it does
not fall under any of the above exceptions. Thus, the Supreme Court dismissed the petition, but in
the light of compassionate equity, students who were, in view of the absence of academic
deficiencies, scheduled to graduate during the school year when the petition was filed, should be
allowed to re-enroll and to graduate in due time.