Saint Louis University, Inc. v. Olairez

 Saint Louis University, Inc. v. Olairez, 

G.R. No. 197126, 

January 19, 2021

DOCTRINE: As provided by Article 14, section 5 (2) of the Constitution, Academic

freedom shall be enjoyed in all institutions of higher learning. Academic freedom, as

worded in our Constitution, is granted to institutions of higher learning. It is different from

the academic freedom granted to individuals such as students and professors, who

have the right "to seek and express truth" in their academic work. This type of academic

freedom is separate and distinct from academic freedom which refers to the autonomy

of academic institutions as a corporate body.

FACTS:

In this case, the petitioner Saint Louis University, Inc. (SLU) imposed as a requirement

for graduating medicine students the passing of a Comprehensive Written Examination

wherein all candidates for graduation were required to take a written examination

consisting of 100 multiple-choice type questions for each of their 12 subject areas.

Those who will fail shall be required to take a remedial examination for that particular

subject area alone. After sometime, the newly-appointed Dean of the SLU College of

Medicine, issued new guidelines for a Revised COWE for school year 2001-2002

wherein one written examination and introduced two oral exercises. Candidates for

graduation who pass the written examination shall be exempted for the first oral

exercise (Orals I) and proceed to the second oral exercise (Orals II), while those who

fail the written examination shall be required to take Orals I followed by Orals II.

Students who fail Orals I shall be required to render at least two months of extended

clerkship.

In line with this, the respondents who were in the fourth and final year of their medical

education sought judicial intercession by filing the subject complaint with the RTC.

Thereafter, an ex-parte restraining order, for a period of 72 hours, was issued by the

Executive Judge. The case was then raffled to another judge who, in tum, issued a

temporary restraining order against the further implementation of the Revised COWE.

During the pendency of the case before the trial court, respondents were able to

complete their respective clerkships with passing marks. However, SLU refused to

release all of the pertinent documents to enable them to begin their medical internships,

to wit: certificates of graduation, transcripts of records and diplomas. Nonetheless, the

Commission on Higher Education (CHED) issued certifications stating that respondents

had completed all of the academic requirements for the degree of Doctor of Medicine.

ISSUES:

Whether or not the imposition of the Revised COWE is reasonable exercise of its

academic freedom, justified by the public policy on the need to elevate the standards of

medical education?

HELD:

No. The Court held that when an academic institution accepts students for enrollment,

there is established a contract between them, resulting in bilateral obligations which

both parties are bound to comply with. In this case, the relationship between SLU and

respondents was encapsulated in the 2001 Student Handbook which clearly defined the

parameters for respondents to obtain their Doctor of Medicine degrees which, as far as

their respective official transcripts of records are concerned, they did. SLU' s immediate

imposition of the Revised COWE is capricious and inconsistent with an institution of

higher learning's contractual obligation to afford its students a fair opportunity to

complete the course they seek to pursue.