1.Unciano Paramedical College Inc. v. CA, G.R. No. 100335, April 7, 1983.

FACTS:

On April 16, 1990, private respondents filed a petition for injunction and damages against the
petitioner alleging among others that they were barred from enrollment for second semester in the College
of Nursing because they supposedly harassed a female student, invited an outsider to the school to speak
before the students and also because the school has an arrangement with DepEd not to allow their
students to put up a student council.

The Trial Court favored the arguments of the private respondents. When elevated to the CA, CA
dismissed the petition of the petitioner for lack of merit. The Court culled its decision based on a recent
decided case of Ariel Non, et. Al. v. Hon. Sacho Dames II, et. al., G.R.No. 89317, May 20, 1990 and not
on the earlier case of ALCUAZ, et. al. v. Philippine School of Business Administration, Quezon City
Branch, with G.R. No. L-76353, May 2, 1988.

ISSUE: W/N the Non Doctrine should be applied retroactively to govern and invalidate the legal effects
of incidents that took place prior to its adoptions and which incidents were proper and valid under the
Alcuaz Doctrine prevailing at the time said incidents took place?

HELD:

“Art. 4. Laws shall have no retroactive effect, unless the contrary is provided.”

No, prospective application must be followed. The ruling in Non Case should not be given a
retroactive effect to cases that arose before its promulgation on May 20, 1990, as in this case which was
filed on April 16, 1990. To do otherwise would be oppressive. The Court reiterate the pronouncement in
People v. Jabinal, G.R. No. L-30061, (1974), it is a settled rule that when a doctrine of this Court is
overruled and a different view is adopted, the new doctrine should be applied prospectively, and should
not apply to parties who had relied on the old doctrine and acted on the faith thereof.