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UNIVERSITY OF EAST v. ROMEO A. JADER

FACTS:

The petitioner, University of the East (UE), is being sued for damages by the respondent, Romeo A. Jader, for misleading him into believing that he had fulfilled all the requirements for graduation when this was not the case. Jader was enrolled in UE's College of Law from 1984 to 1988. In the first semester of his last year, he was given an incomplete grade for Practice Court I. Jader applied for the removal of the incomplete grade and took the examination in March 1988. On May 30, 1988, Jader received a failing grade of five (5). However, his name appeared in the tentative list of candidates for graduation for the second semester of 1987-1988. The list included an annotation stating that degrees will only be conferred upon those who satisfactorily complete the requirements. Jader attended the investiture ceremonies and went up the stage when his name was called. He even had pictures taken during the occasion. Jader later prepared himself for the bar examination but dropped his review class upon learning of the deficiency in his grades. He was not able to take the bar examination. Jader sued UE for damages, claiming that he suffered various damages as a result of UE's negligence. The trial court ruled in favor of Jader and ordered UE to pay damages. The Court of Appeals affirmed the decision with modification, increasing the amount of damages. UE appealed to the Supreme Court, but the Court denied the appeal, stating that the school had the obligation to timely inform and furnish sufficient notice to the students regarding their graduation requirements. The Court also acknowledged that students are not duty-bound to deal with the school's agents, such as professors, regarding their grades.

ISSUES:

  1. Can an educational institution be held liable for damages for misleading a student into believing that he had satisfied all the requirements for graduation?

  2. Did the petitioner commit negligence in not verifying the result of his removal exam?

RULING:

  1. Yes, an educational institution can be held liable for damages for misleading a student into believing that he had satisfied all the requirements for graduation. The Court held that when a student is enrolled in an educational institution, a contract of education is entered into between the institution and the student. It is the contractual obligation of the school to timely inform and furnish sufficient notice and information to each student as to whether they had already complied with all the requirements for the conferment of a degree or whether they would be included among those who will graduate. By including the student's name in the tentative list of graduating students and inviting him to the commencement ceremony, the school gave the impression that he had completed all the requirements for graduation. The school cannot evade liability by claiming that it only provided a tentative list and that degrees will only be conferred upon those who satisfactorily complete the requirements.

  2. No, the petitioner did not commit negligence in not verifying the result of his removal exam. The Court ruled that the responsibility to inform the student of any deficiency or problem involving his grades lies primarily with the school. The student is not duty-bound to personally verify from the professor concerned the result of his removal exam. The professor's duty is to directly furnish the student his grades. It is the school's obligation to ensure that students are promptly informed of any issues regarding their graduation.

PRINCIPLES:

  • When a student is enrolled in an educational institution, a contract of education is entered into between the institution and the student.

  • The responsibility to timely inform and furnish sufficient notice and information to each student as to whether they had already complied with all the requirements for graduation lies with the school.

  • Including a student's name in the tentative list of graduating students and inviting him to the commencement ceremony gives the impression that he had completed all the requirements for graduation.

  • The student is not duty-bound to personally verify from the professor concerned the result of his exams or grades. It is the school's responsibility to ensure that grades are promptly furnished to the students.

  • Commencement ceremonies are not ordinary occasions and serve as the educational institution's way of announcing to the whole world that the students included in the list of those who will be conferred a degree have satisfied all the requirements.