Laxamana v. Borlaza
REITERATIONFacts
The Antecedents: Felicitas P. Laxamana, Director of Publications of the Philippine Normal College (PNC), filed a complaint against Dr. Gregorio C. Borlaza, PNC President. Laxamana alleged that two memoranda issued by the President—one requesting more care in student publications and proposing review of page proofs, and another establishing a Board of Management for student organs—violated constitutional liberties of thought, speech, and press, academic freedom, and the State's obligations. Laxamana also claimed the President intended to remove her from her post. Procedural History: The Court of First Instance (CFI) denied Laxamana's prayer for a preliminary injunction. Subsequently, Laxamana was relieved as Director of Publications and assigned to full-time teaching, pursuant to a Board of Trustees resolution. She filed supplemental complaints seeking damages. The CFI dismissed the complaint, finding the directives were within the President's administrative authority and that Laxamana's relief was valid as she held the position by designation, not permanent appointment. Laxamana appealed. The Petition: Laxamana appealed the CFI's decision, maintaining that the directives were unconstitutional and that her relief as Director of Publications was a denial of due process.
Issue(s)
Whether the two memoranda issued by the PNC President abridged constitutional liberties and academic freedom. Whether Laxamana was denied due process when she was relieved as Director of Publications.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance, dismissing the complaint. The Court found that the questioned directives were issued within the legitimate exercise of the President's administrative and supervisory authority for the orderly management and discipline of the college. Furthermore, Laxamana's relief as Director of Publications was deemed valid as she held the position by designation, not permanent appointment, and the Board of Trustees had the authority to withdraw such designation.
Ratio Decidendi
On the alleged unconstitutionality of the memoranda: The Court found that the arguments regarding the unconstitutionality of the directives had become academic. The first memorandum's suggestion for page proof review was recalled. The second memorandum, which merely requested the Board of Management to restudy policies for improvement, was not seen as an abridgment of liberties, especially since the President's concern was about the quality of student writing not meeting acceptable standards of fairness. The Court emphasized that at that stage, there was no actionable violation or threat of violation of constitutional liberties. On the denial of due process in relief as Director of Publications: The Court clarified that there was no specific position of "Director of Publications" in the official plantilla of the PNC, and that Laxamana held the position by designation, not permanent appointment. Her appointment as "Associate Professor II (Range 48) (Director of Publications)" meant her promotion to Associate Professor II did not terminate her designation as Director of Publications. Since the designation was not a permanent appointment, she could be shifted to full-time teaching duties without it constituting an illegal removal. The Court noted that Resolution No. 85 of the Board of Trustees authorized the President to shift professors between administrative and professorial jobs, and her shift was authorized by the Board itself through Resolution No. 606. The Court concluded that the Board had the power to withdraw her designation without affecting her salary, rank, or status, rendering the question of whether she was heard not decisively relevant.
Main Doctrine
The exercise of administrative and supervisory authority by an educational institution's president for the orderly management and preservation of discipline is legitimate, and a designation to an administrative position, not being a permanent appointment, can be withdrawn without violating due process, especially when authorized by the Board of Trustees.