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.
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