Case Digest: University of the East v. Romeo A.

Jader
G.R. No. 132344, February 17, 2000

Facts:

Romeo A. Jader, the respondent, was enrolled in the University of the East's College of Law
from 1984 to 1988. During the first semester of his last year (school year 1987-1988), he failed
to take the regular final examination in Practice Court I and was given an incomplete grade. He
enrolled for the second semester as a fourth-year law student and applied for the removal of the
incomplete grade, which was approved after paying the required fee. He took the examination
and received a failing grade.

In the period following his examination, the Dean and Faculty Members of the College of Law
deliberated on which fourth-year students were eligible to graduate. Jader's name appeared on
the tentative list of candidates for graduation, with a note indicating a deficiency in a specific
subject. However, the invitation to the commencement ceremony included his name among the
candidates. During the ceremony, Jader's name was called, he went on stage, received a
diploma symbol, and had his picture taken.

Later, Jader learned of his deficiency and was unable to take the bar examination. He filed a
lawsuit against the University of the East (petitioner) for damages, claiming he suffered
emotional distress and reputational harm due to the University's negligence. The trial court ruled
in favor of Jader, ordering the University to pay damages. The Court of Appeals (CA) upheld the
decision with modification, adding an amount for moral damages.

Issue:

Whether or not the University could be held liable for damages due to misleading a student
regarding his graduation status.

Ruling:

The Supreme Court upheld the lower courts' decisions in favor of Jader. The Court emphasized
the application of Article 19 of the Civil Code, requiring all to act with justice, honesty, and good
faith. The University's failure to communicate Jader's deficiency breached these principles.

Also, Article 20 of the Civil Code states that those causing damage due to negligence must
indemnify. The University's negligent inclusion of Jader's name caused emotional distress and
career harm, invoking Article 20.

The Court held that educational institutions bear a duty of care, making them accountable for
their actions. The University's misleading conduct made it liable for damages.
The Supreme Court affirmed the Court of Appeals' decision. The case underscores that
educational institutions must uphold integrity, guided by the principles of the Civil Code. The
University was directed to compensate Jader, aligning with justice and legal ethics.