Capitol Medical Center, Inc. v.

Court of Appeals
GR # L-82499 | 178 SCRA 493 | October 13, 1989
Petition: Petition for Review of Writ of Preliminary and Mandatory Injunction
Petitioner: Capitol Medical Center, Inc. & Dra. Thelma Navarrete Clemente
Respondent: Hon. Judge Ignacio Salvador & Monina Reyes-Valenzuela et al.
(Article 1305 of the Civil Code, Contracts)
DOCTRINE
The contract between a school and a student enrolled and paid the fees for a
semester, is for the entire semester only, and not for the entire course. The law
does not require a school to see a student through to the completion of his course. If
the school closes or is closed by proper authority at the end of a semester, the
student has no cause of action for breach of contract against the school.
FACTS
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Petitioner Capitol Medical Center, Inc. (CMCI), a hospital corporation,

opened and operated the Capitol Medical Center College (the school).
o The college offered a four-year nursing course, and two-year
courses on midwifery and medical secretarial courses.
o Halfway through the first semester, the faculty demanded that they
be granted vacation leave and sick leave privileges.
o Despite the dialogues between the administration led by its
president, petitioner Dra. Clemente, and the faculty, no agreement
was reached.
o The hostilities aggravated. The CMCI Board, through its resolution,
authorized petitioner Clemente to close down the school, which
then resulted to a demonstration by the students and teachers.
o Finally, a public announcement was posted which ordered for the
closing down of the school, and that students were advised to
transfer to other schools.
Petitioner CMCI then wrote (twice) to the Department of Culture and Sports
(DECS), informing them of the closing down of the school.
o DECS approved for a gradual closing down of the school.
However, CMCI only intended to inform them of their action.
o Teachers, students, and parents requested to open the school until
the end of the school year.
o An agreement was prepared by the DECS, but CMCI wanted to
include a stipulation providing that no rallies or demonstrations are
to be held until the end of the school year.
o The agreement, however, was not signed; the school did not
reopen.
Private respondents (students and parents) filed a class suit.
o Respondents prayed for the reopening of the school until the end of
the school year.
The RTC granted the petition ordering petitioners to reopen the school and
allow its students to enroll in their respective courses.
The CA affirmed the decision of the trial court.
o That petitioners had no right to close the school for the enrollment
of the students created a binding contract between the parties

That the school should continue to operate until the students shall
have finished their courses

Hence, this petition for review.

ISSUE/S
1. W/N the writ of preliminary injunction, preserving the status quo, is proper NO
2. W/N respondents have a legal right to reopen the school and be readmitted NO
PROVISIONS
Art. 1305. A contract is a meeting of the minds between the two parties, whereby one
binds himself, with respect to the other, to give something, or to render some service.
RULING & RATIO
1. NO
The preliminary injunction, which reverts to the status quo, does more than
what it should do.
The status quo being referred to is the time prior to the closing of the school
o This was the time when the schools were deserted; the students
and teachers refused to hold classes; demonstrations are taking
place
[T]he continued operation of the CMCC futile and untenable. The college
had no reason to remain open under the situation which the private
respondents themselves brought about.
2.

NO
The CA erred in its theory that initial enrollment of students created a
binding contract between the school and the students, rendering them
legally and morally bound to continue operations until the students have
finished their courses
[T]here is no contract between him and the school for the latter to remain
open for the entire duration of his course.
o Manual of Regulations of Private Schools (Section VII, par. 137)
o See DOCTRINE.

DISPOSITION
WHEREFORE, the petition for review is granted. The decision of the Court of Appeals
is hereby set aside. The order and writ of preliminary mandatory injunction issued by
the Regional Trial Court of Quezon City, Branch 77 are hereby annulled and set
aside. Costs against the private respondents.
NOTES
1. Cruz, J. concurring:
o I also have my misgivings about the ruling of the Court that a
student's enrollment is from semester to semester and may be
terminated at will by the school after each period. I submit that
when a student is enrolled for a particular course, the implicit
understanding is that he is entitled to remain in the school until he
graduates, subject only to the usual academic, financial and other
reasonable requirements.
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