ATENEO DE MANILA UNIVERSITY VS. HON.

JUDGE IGNACIO CAPULONG

G.R. No. 99327, May 27, 1993

Facts:
Leonardo Villa, a first-year law student of petitioner university, died due to
serious physical injuries after the initiation rites of Aquila Legis. Petitioner Dean
Del Castillo created a Joint Administration-Faculty-Student Investigating
Committee in order to investigate and submit a report within 72 hours on the
circumstances surrounding the death of Villa. Said notice also required
respondent students to submit their written statements within 24 hours from
receipts. Although students received a copy of the same, they failed to file a reply.
After receiving statements and testimonies of several witness the Committee
found respondent students guilty for violation of Rule 3 of Law School Catalogue
entitled “Discipline” which prohibits participation in hazing activities. Accordingly,
Fr. Bernas imposed the penalty of dismissal on all respondent students. The latter
then filed a TRO before RTC and the same was granted. Upon expiration of the
TRO, Den Del Castillo created a Special Board to investigate the charges of hazing
against Abas and Mendoza. The latter requested it to be stricken out such that the
creation of the Special Board was totally unrelated to the original petition which
alleged lack of due process.

Issue:
Whether respondent students have afforded procedural due process prior
to their dismissal from petitioner university.

Ruling:
The Court holds that there was no denial of due process, particularly,
procedural due process. Dean of the Ateneo law School notified and required
respondent students to submit their written statement regarding the incident.
However, they failed to comply on such. The nature and cause of accusation were
adequately spelled out in petitioners’ notices. It is then evident that the twin
elements of procedural due process are present, that is, notice and hearing.