Reyes v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the admission of certain students to the University of the Philippines College of Medicine (UPCM). Applicants who scored above the 70th percentile on the National Medical Admission Test (NMAT) were initially considered qualified for the academic year 1986-1987, as approved by the University Council. However, the UPCM Faculty later attempted to raise this cutoff to the 90th percentile for the academic year 1987-1988 without the requisite University Council approval. This led to a protracted legal battle over whether these students, who met the initially approved 70th percentile cutoff, should be admitted. 2. Procedural History: The controversy began when the Board of Regents (BOR), in response to appeals, reverted the NMAT cutoff score to the 70th percentile. Despite directives from the BOR, the UPCM Faculty and Dean refused to admit the students. This prompted the students to file a mandamus petition with the Regional Trial Court (RTC), which issued a preliminary injunction for their admission. The BOR subsequently passed a resolution affirming the University Council's authority over admission requirements. An earlier petition concerning the RTC's order was dismissed by the Supreme Court. Later, after the students sought to withdraw their court action due to perceived lack of moral standing, the UPCM Faculty denied their appeal for admission. This led the students to file a motion to reconsider the dismissal, resulting in an RTC order for their admission. The BOR then issued its own resolution approving the students' admission. The petitioners challenged this BOR resolution before the Court of Appeals (CA), which upheld the BOR's decision. The petitioners also appealed the RTC's orders regarding contempt and injunction to the CA, which dismissed their petition. These CA decisions form the basis of the current petitions before the Supreme Court. 3. The Petition: The petitioners, including faculty members and administrators of the University of the Philippines, filed two petitions for certiorari and prohibition (G.R. No. 94961) and certiorari and mandamus (G.R. No. 96491) with the Supreme Court. They seek to reverse the decisions of the Court of Appeals, which affirmed the Board of Regents' resolution ordering the admission of the students and upheld the RTC's orders. The petitioners argue that the BOR's resolution was ultra vires and violated academic freedom, asserting that the College Faculty has the authority to set admission requirements. They also contend that the students' own letter indicated they had no moral right to admission, rendering the case moot. The petitions also sought the disqualification of a Justice from participating in the deliberation of one case.
Issue(s)
Whether the Board of Regents (BOR) could validly direct the admission of students to the College of Medicine. Whether the Court of Appeals erred in dismissing the petitions, rendering the issues moot and academic. Whether the petitioners' claim of academic freedom was violated by the BOR's resolution. Whether the students' letter to the Faculty constituted a judicial confession of lack of legal right to admission.
Ruling
The petitions are DISMISSED, and the decisions of the Court of Appeals dated August 14, 1990, and September 5, 1990, are AFFIRMED.
Ratio Decidendi
On the authority of the Board of Regents (BOR) to direct admission: The Supreme Court affirmed the BOR's power of governance and administration over the University of the Philippines (UP), as vested by its Charter (Act No. 1870). While the University Council (UC) has the power to fix admission requirements, the BOR, as the highest governing body, has the duty to step in and correct anomalies or abuses in the exercise of this power. The BOR's 1031st resolution, directing the admission of the students, was a valid exercise of its oversight function to ensure compliance with law and university regulations, especially since the faculty's attempt to change the NMAT cut-off score to 90 percentile lacked the UC's approval and was thus legally inefficacious. The Court emphasized that the BOR did not assume a power it did not possess but rather exercised its duty to uphold the law and existing approved requirements. On the mootness of issues: The Court agreed with the Court of Appeals that the issues concerning the validity of the BOR's earlier resolutions (996th and 997th) and the students' qualification for admission had become moot. This was due to the CA's prior decision (August 14, 1990) which had already passed upon these arguments in totality, as they were inextricably linked to the validity of the BOR's 1031st resolution. The petitioners' own petition in G.R. No. 94691 had admitted that the appellate court passed upon the issue raised before the RTC, thus validating the finding of mootness. On the violation of academic freedom: The Court held that the petitioners' claim of academic freedom was unsubstantiated. Academic freedom, as it pertains to admission requirements, is vested in the University Council by law. The College Faculty's power to initially determine these requirements is subject to the UC's approval. The BOR's resolution, which upheld the UC-approved admission requirement, did not violate the faculty's academic freedom but rather corrected an unauthorized exercise of power by the faculty and dean who attempted to change the requirements without proper approval. The faculty's rights as university teachers remained unaffected by the BOR's directive. On the students' letter as a confession: The Court found that the students' letter to the Faculty, stating they felt they had "no moral right" to pursue court action, did not constitute a categorical admission of the absence of a legal right. The statement was tinged with doubt and appeared to stem from a sense of hopelessness due to perceived adverse circumstances and the advice of the UP President, rather than a firm realization of lacking a legal basis for their admission. The Court noted the "three agonizing years of uncertain relationship" and the students' proximity to graduation as factors influencing their letter, and concluded that such a statement, even if considered an admission, involved a conclusion of law based on a misapprehension of their legal rights.
Main Doctrine
The Board of Regents (BOR) has the power of governance and administration over the University of the Philippines (UP), including the authority to ensure compliance with laws and regulations. While the University Council (UC) has the primary authority to fix admission requirements, the BOR can intervene to correct anomalies or abuses in the exercise of this power. The faculty's claim of academic freedom regarding admission requirements is limited by the UC's statutory power.