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KHRISTINE REA M. REGINO v. PANGASINAN COLLEGES OF SCIENCE

FACTS:

Khristine Rea M. Regino was a first-year computer science student at Pangasinan Colleges of Science and Technology (PCST). Regino refused to pay for tickets to a school fundraising event called the "Rave Party and Dance Revolution" due to financial constraints and religious beliefs. The school allegedly compensated students who purchased tickets with additional points in their test scores and denied those who refused to pay from taking final exams. Regino's teachers, Rachelle A. Gamurot and Elissa Baladad, allegedly disallowed her from taking the logic and statistics exams respectively for failing to pay for the tickets. Regino filed a complaint for damages against PCST, Gamurot, and Baladad. The respondents filed a motion to dismiss on the ground of failure to exhaust administrative remedies. The trial court dismissed the complaint for lack of cause of action, ruling that the Commission on Higher Education (CHED) had jurisdiction over the matter. Regino filed a petition for review before the Supreme Court, raising the issues of whether exhaustion of administrative remedies applies and whether the complaint stated sufficient cause(s) of action.

ISSUES:

  1. Whether the petitioner is required to exhaust administrative remedies before resorting to the RTC.

  2. Whether the complaint states a cause of action.

  3. Whether there was a breach of contract by the defendants.

  4. Whether the defendants are liable for tort.

  5. Whether the imposition of the dance party fee is valid.

  6. Whether a school can be held liable for tort even if there is an existing contract between the school and the student

  7. Whether academic freedom of an institution can be invoked as a defense against liability for tort

  8. Whether or not the complaint alleges sufficient causes of action against respondents.

  9. Whether or not the trial court erred in summarily dismissing the complaint.

RULING:

  1. The doctrine of exhaustion of administrative remedies is not applicable in this case since the petitioner is seeking damages, which is beyond the jurisdiction of the CHED and within the jurisdiction of the courts. The CHED does not have the power to award damages. Furthermore, the issue in this case is purely legal and falls within the jurisdiction of the trial court. Therefore, the petitioner is not required to exhaust administrative remedies before filing the case.

  2. The complaint contains sufficient causes of action. The respondents did not dispute any of the petitioner's allegations in their Motion to Dismiss. The allegations in the complaint, if true, would entitle the petitioner to the relief prayed for. A reexamination of the complaint is warranted.

  3. Yes, there was a breach of contract by the defendants. The relationship between the school and the student is considered a contract, and the school has an obligation to provide students with education and abide by the terms set forth in the contract. The defendants' refusal to allow the plaintiff to take the examination constitutes a breach of this contractual obligation.

  4. The defendants may be liable for tort. The allegations in the case show that the defendants ejected the plaintiff from the classroom and refused to give her a chance to take the examination, which caused her harm and damages. This may give rise to a cause of action for tort.

  5. The imposition of the dance party fee is not valid. The fee was not part of the school-student contract entered into at the start of the school year, and therefore, it could not be unilaterally imposed to the prejudice of the enrollees.

  6. Yes, a school can be held liable for tort even if there is an existing contract between the school and the student. Liability for tort can arise even when there is a contract, as the act that violates the contract may also be a tort. Obligations arising from tort can arise between parties not otherwise bound by contract. (PSBA vs. CA)

  7. No, academic freedom cannot be invoked as a defense against liability for tort. Academic freedom encompasses the independence of academic institutions to determine who may teach, what may be taught, how it shall be taught, and who may be admitted to study. However, once a school has set its standards, these should be meticulously observed and should not be used to discriminate against certain students. Academic freedom should not be used to justify acts that violate the rights and dignity of students. (Garcia v. Faculty Admission Committee; Tangonan v. Paño)

  8. The Court holds that the complaint alleges sufficient causes of action against respondents.

  9. The trial court erred in summarily dismissing the complaint.

PRINCIPLES:

  • The doctrine of exhaustion of administrative remedies is not applicable when the issue involves a claim for damages, which is beyond the jurisdiction of the administrative body. It is also not applicable when the issue is purely legal and falls within the jurisdiction of the courts.

  • A complaint states a cause of action if it sufficiently alleges facts that, if true, would entitle the plaintiff to the relief prayed for. A motion to dismiss based on lack of cause of action hypothetically admits the truth of the alleged facts.

  • The relationship between the school and the student is considered a contract, and it is characterized as a reciprocal relationship.

  • The school undertakes to provide education to students, while the students agree to abide by academic requirements and observe the school's rules and regulations.

  • The terms of the school-student contract are defined at the moment of enrollment, and the school informs prospective enrollees of the amount of fees and the terms of payment.

  • Failure to pay financial obligations can be a valid ground for the school to deny students the opportunity to take examinations.

  • Students expect that upon their payment of tuition fees and satisfaction of academic requirements, the school would recognize their completion of the course.

  • An institution of higher learning has a contractual obligation to afford students a fair opportunity to complete the course they seek to pursue, barring any violation of the rules on the part of students.

  • Imposing fees or conditions not stipulated in the school-student contract can be considered a breach of contract.

  • School-student contract is imbued with public interest and is subject to the Constitution and supervisory and regulatory powers of the State.

  • Students have the right to select a profession or course of study, subject to fair, reasonable, and equitable admission and academic requirements.

  • Students have the right to choose their field of study, subject to existing curricula, and to continue their course until graduation, except in cases of academic deficiency or violation of disciplinary regulations.

  • Liability for tort can arise between parties not otherwise bound by contract, as the act that violates the contract may also be a tort.

  • Academic freedom encompasses the independence of academic institutions to determine who may teach, what may be taught, how it shall be taught, and who may be admitted to study.

  • Academic freedom should not be used to discriminate against certain students or to justify acts that violate the rights and dignity of students.

  • Schools have a contractual obligation towards their students and should not discriminate against certain students.

  • Once students are accepted upon enrollment, the school cannot renege on its contractual obligation on grounds other than those made known to, and accepted by, students at the start of the school year.