Ateneo vs Court of Appeals GR 56180 16 October 1986

Facts:

Juan Ramon Guanzon was a student-boarder at Cervini hall who hurled abuses and laid
hand to the cafeteria server. This was witnessed by several boarders. The university
investigated the slapping incident and decided to expel Guanzon. He opted instead to
apply for honourable dismissal which was granted. Upon learning of the incident, his
parents lodged a complaint for damages with CFI on the ground of unfair trial. The
university denied this and justified that such behaviour of the student is subject to be
sanctioned by the school 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. Lower court decided in favour of the
Guanzon. CA initially reversed the LC decision. Upon motion for reconsideration of the
Guanzons, CA reversed it’s own decision. Ateneo was compelled to ask for review of the
said decision.

Issue:

Whether or not Guanzon was denied due process on the ground of unfair trial?

Decision:

Petition granted. Juan Ramon himself appeared before the Board of Discipline. He
admitted the slapping incident. He was given notice of the proceedings; he actually
appeared to present his side; the investigating board acted fairly and objectively; and
all requisites of administrative due process were met. The court does not share the
view that there was no due process because the parents of Guanzon was not given any
notice of the proceedings. He, who at the time was 18 years of age, was already a
college student, intelligent and mature enough to know his responsibilities. He is
assumed to have reported this serious matter to his 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 petitioner university.