ADMU v CA

GR No. L-56180
Petitioner: Ateneo de Manila University
Respondents: Court of Appeals, and Spouses Romeo G.
Guanzon and Terresita Regalado
Ponente: Gutierrez, Jr., J.
Date: October 16, 1986
TOPIC: Procedural Due Process
DOCTRINE
Due Process in administrative proceeding requires
consideration of evidence presented and existence of
evidence to support the decision.
SHORT VERSION
Juan Ramon Guanzon (son of private respondents)
slapped Carmelita Mateo, a waitress in the cafeteria of
Cervini Hall inside the university campus of the
petitioners. Guanzon was charged with unbecoming
conduct and was subjected to the rules and regulations of
the Ateneo. Eventually, Guanzon was dropped from the
rolls of students. The respondents brought action to
courts alleging that their son was not given due process
and the school violated their sons constitutional rights.
RTC rules in the favor of the respondents. CA reversed,
but through respondents Motion for Reconsideration CA
upheld RTC ruling.
SC reviewed the facts of the case since they believe CA
erred in their findings of facts. SC found that Ateneo
observed all proceedings needed and there was no
arbitrariness in their decision. There was no breach of
due process.
FACTS
Juan Ramon Guanzon, a boarder of Cervini (campus
dormitory) ordered a siopao in the cafeteria. Carmelita
Mateo told Guanzon that the siopao has to be heated and
he need to wait for a while. Guanzon then started
mumbling rude words and when Carmelita asked him to
stop he replied that it was not her business. Carmelita
offered to return his money back but Guanzon refused.
Instead, he hit Carmelita on the temple then his friends
restrained him before he could strike again while
Carmelita hid in the kitchen.
Because of his unbecoming behavior, he was subjected
as a student to the universitys disciplinary regulations

action and sanction. After the investigation (see ratio [1]

for details), Guanzon was dismissed from the university.
His parents filed a suit against Ateneo alleging that there
was no due process in the dismissal of their son and that
they should be awarded moral damages.
ISSUES/HELD
(1) WoN there was due process in the administrative
proceeding in hearing the disciplinary case of
Guanzon.-YES
(2) WoN the Respondents should be awarded for moral
damages - NO
RATIO
(1) SC held that there was due process in the
administrative proceeding of Ateneo in hearing the
disciplinary case. Guanzon 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
inet.
>First, Guanzon was given notice of his case and the
proceedings. He was even asked to bring the matters to
the knowledge of his parents, which he however did not
do and instead he presented his case alone. >Second, He
admitted the truth of the charge.
>Third. Ateneo sought the help of their offices who are
expert in dealing with disciplinary cases. (ie. Student
counselor, Director of Guidance)
>Fourth, The decision for expulsion was unanimous and
none moved to contest it except the President of the
student council who filed a motion for reconsideration
which was later dismissed.
>Fifth, As the decision for expulsion was to be carried
out Guanzon filed for a Honorable dismissal which the
University later granted.
>Sixth, When the respondents asked for a full refund of
tuition for that semester, it was given out by the Ateneo.
The contention for the breach of due process was
grounded on the fact that the parents were
uninformed during the proceeding. The court however
held that it was not the fault of the university. Guanzon,
being an 18 years-old, is fully responsible for his
actions. He chose to remain silent about the issue even
when he went back to his province for the Christmas
vacation. The University cannot be held at fault.
It was also found that Carmelita also tried to hit
Guanzon with a cupboard box, but despite this, Guanzon
was not justified since it was him who started the
commotion. The altercation started with Guanzons

utterance of the offensive language bilat ni bay an

Ilonggo phrase which means sex organ of a woman. It
was normal for Mateo to react to the nasty manner.
The offense constituted a ground for dismissal and the
Court found to arbitrariness in the proceeding of the
case. SC held that there was due process in the
proceeding and there was not violation of Guanzons
constitutional rights.

of their son and his unbecoming behavior. There was no

bad faith on the part of the university. The whole
procedure of the disciplinary process was set up to
protect the privacy of the students involved. There is
absolutely no indication of malice, fraud, and improper
of willful motives or conduct on the part of the Ateneo
de Manila university.
DECISION

(2) The court held that no moral damages can be granted

despite the fact that the respondents were part of a
known family in their province and that they suffered
humiliation in the dismissal of their son. The court found
that the family suffered humiliation because of the fault

Judgement reversed.
O