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Ateneo v.

CA [GR L-56180, 16 October 1986] Second Division, Gutierrez (J): 4 concur, 1


took no part Facts: On 12 December 1967, Juan Ramon Guanzon (from Bacolod, son of Romeo
Guanzon and Teresita Regalado), first year student of AdMU Loyola Heights, and boarder at the
Cervini Hall) struck at the left temple of Carmelita Mateo, a waitress in the Cervini Hall cafeteria.
Other boarders held him from striking again, but the boarders hid the incident from Fr. Campbell.
The university conducted an investigation of the slapping incident. On the basis of the investigation
results, Juan Ramon was dismissed from the university. The dismissal of Juan Ramon triggered off
the filing of a complaint for damages by his parents against the university in the then Court of First
Instance (CFI) of Negros Occidental at Bacolod City. The complaint states that Juan Ramon was
expelled from school without giving him a fair trial in violation of his right to due process and that
they are prominent and well known residents of Bacolod City, with the unceremonious expulsion of
their son causing them actual, moral, and exemplary damages as well as attorney's fees. In its
answer, the university denied the material allegations of the complaint and justified the dismissal of
Juan Ramon on the ground that his unbecoming behavior is contrary to good morals, proper
decorum, and civility, that such behavior subjected him as a student to the university's disciplinary
regulations' action and sanction and that the university has the sole prerogative and authority at
any time to drop from the school a student found to be undesirable in order to preserve and
maintain its integrity and discipline so indispensable for its existence as an institution of learning.
After due trial, the lower court found for the Guanzons and ordered the university to pay them
P92.00 as actual damages; P50,000.00 as moral damages; P5,000.00 as attorney's fees and to pay
the costs of the suit. Upon appeal to the Court of Appeals by the university, the trial court's decision
was initially reversed and set aside. However, upon motion for reconsideration filed by the
Guanzons, the appellate court reversed its decision and set it aside through a special division of
five. The motion for reconsideration had to be referred to a special division of five in view of the
failure to reach unanimity on the resolution of the motion, the vote of the regular division having
become 2 to 1. Hence, the University filed a petition for review before the Supreme Court.

Issue: Whether the absence of notice to the dismissed students parents negates the compliance
of the requirements of administrative due process.

Held: Besides the administrative body undertaking a fair and objective investigation of the
incident, due process in administrative proceedings also requires consideration of the evidence
presented and the existence of evidence to support the decision. Herein, the original Court of
Appeals decision (penned by Justice Gancayco) showed that the procedures in the expulsion case
were fair, open, exhaustive, and adequate. There were nothing in the records to reverse the
findings in the reconsideration. Clearly, there was absolutely no indication of malice, fraud, and
improper or wilful motives or conduct on the part of the Ateneo de Manila University. Juan Ramon
was given notice of the proceedings. He actually appeared to present his side. The investigating
board acted fairly and objectively. All requisites of administrative due process were met. It cannot
be negated by the fact that the parents of Juan Ramon were not given any notice of the
proceedings. Juan Ramon, who at the time was 18 years of age, was already a college student,
intelligent and mature enough to know his responsibilities. He was fully cognizant of the gravity of
the offense he committed as he asked if he could be expelled for what he did. When informed about
the 19 December 1967 meeting of the Board of Discipline, he was asked to seek advice and
assistance from his guardian and or parents. The fact that he chose to remain silent and did not
inform them about his case, not even when he went home to Bacolod City for his Christmas
vacation, was not the fault of the University.