The Supreme Court in Maronilla vs. Jorda addressed the extent of a University President’s power to review decisions of the Student Disciplinary Tribunal (SDT), particularly when it involves the acquittal of students. The Court ruled that while there may not be an express right to appeal such decisions, the University President’s broad authority under the University Code allows for a review, even if prompted by a party without explicit appellate rights. This decision clarifies the balance between institutional authority and student rights within the unique context of university governance.

When Can a University President Overturn a Student Disciplinary Tribunal’s Decision?

This case revolves around a complaint filed by Atty. Ramon Maronilla against Attys. Efren N. Jorda and Ida May J. La’o, both from the University of the Philippines-Diliman Legal Office. Atty. Jorda, representing the Diliman Legal Office, prosecuted Atty. Maronilla’s sons for their alleged involvement in the mauling of a fellow student. The SDT dismissed the complaint against the Maronilla brothers due to insufficient evidence. Subsequently, Atty. Jorda filed a Motion for Partial Reconsideration, which the complainant argued was impermissible under the disciplinary rules. This action led to the complaint against Attys. Jorda and La’o, alleging a violation of professional responsibility and ignorance of the law.

The Integrated Bar of the Philippines (IBP) initially found Atty. Jorda guilty of violating Rule 12.04 of the Code of Professional Responsibility and gross ignorance of the law, recommending a reprimand. The Supreme Court initially approved this recommendation but later reconsidered based on Atty. Jorda’s motion, which highlighted Art. 50 of the University Code. This article grants the University President the power to modify or disapprove any action or resolution of any college or school faculty or administrative body.

Art. 50. [The President of the University of the Philippines] shall have the right to modify or disapprove any action or resolution of any college or school, faculty or administrative body, if in his judgment the larger interests of the University System so requires. Should he exercise such power, the President shall communicate his decision in writing to the body immediately affected, stating the reasons for his action; and thereafter shall accordingly inform the Board of Regents, which may take any action it may deem appropriate in connection therewith.

Atty. Jorda contended that Art. 50 negates the assertion that there is no right to appeal an acquittal by the SDT, as the U.P. President possesses plenary powers. He cited a previous case, U.P. v. Albino, where Art. 50 was invoked to justify a review by the U.P. President. The Supreme Court acknowledged that Art. 50 was not adequately addressed during the IBP proceedings.

The Court emphasized that while the Revised Rules and Regulations Governing Fraternities, Sororities, and Other Student Organizations do not explicitly grant the University prosecutor the right to appeal an SDT decision acquitting a respondent, it does not explicitly bar it either. Rule V, Section 2 grants a penalized respondent the right to appeal, but remains silent on other parties. Section 7, Rule IV, prohibits motions for reconsideration of SDT rulings filed *with* the SDT, not appeals *to* the U.P. President.

Building on this, the Court clarified that the prohibition against motions for reconsideration with the SDT does not preclude an appeal to the U.P. President. The appellate procedure within the university system clearly distinguishes between actions within the SDT and appeals directed to the President. While the rules don’t explicitly authorize Atty. Jorda’s appeal, they also don’t forbid it. The key lies in the University Code and the powers vested in the U.P. President.

The Supreme Court elaborated on the significance of Art. 50, stating that it undeniably allows the U.P. President to reverse an SDT acquittal recommendation. Even if the University prosecutor’s action was framed differently, the President could still act on the information and reverse the SDT decision. This interpretation aligns with past practices within the university, as demonstrated by prior U.P. Presidents’ actions.

The Supreme Court referenced President Nemenzo’s decision, noting that while he acknowledged the lack of jurisdiction over a formal appeal from the University Prosecutor, he considered the motion for partial reconsideration as a means to highlight potential errors by the SDT. Similarly, the Albino case demonstrated the President’s power to review SDT decisions, even in cases of acquittal, based on Article 50 of the Revised University Code.

The Court underscored that Atty. Jorda demonstrated the absence of a definitive prohibition against a party other than the respondent from seeking review by the U.P. President. While the power of review may be exercised independently, the President is not barred from considering a written appeal from any party. The absence of a statutory right to appeal means that parties cannot demand the President’s consideration, but it doesn’t prevent the President from exercising their authority under Art. 50.

The initial resolution hinged on the principle that appeals require express legal authorization. However, the Court tempered this strict application in light of Art. 50, which authorizes the U.P. President to consider appeals filed by parties like Atty. Jorda. While this may create a form of “backdoor appeal,” the Court recognized the legal framework within the U.P. system and determined that Atty. Jorda’s actions were permissible within that framework. This means that his actions were not contrary to law, and therefore, he could not be held liable for gross ignorance of the law or violation of the Code of Professional Responsibility.

FAQs

What was the central issue in this case?	The case centered on whether a University Prosecutor could appeal a decision of the Student Disciplinary Tribunal (SDT) acquitting students, considering the powers of the University President under the University Code.
What is Article 50 of the University Code?	Article 50 grants the University President the authority to modify or disapprove any action or resolution of any college, school, faculty, or administrative body within the University of the Philippines system, if the larger interests of the University so require.
Did the University Prosecutor have an explicit right to appeal the SDT decision?	No, the Revised Rules and Regulations Governing Fraternities, Sororities, and Other Student Organizations do not explicitly grant the University Prosecutor the right to appeal an SDT decision acquitting a respondent. The rules primarily focus on the rights of the respondents.
How did the Supreme Court interpret the University President’s power in this case?	The Supreme Court interpreted the University President’s power under Article 50 as allowing the President to review and potentially reverse an SDT decision, even in the absence of an explicit right to appeal by the University Prosecutor.
Was the University Prosecutor found guilty of any wrongdoing?	No, the Supreme Court ultimately ruled that the University Prosecutor was not guilty of gross ignorance of the law or violating the Code of Professional Responsibility, as his actions were deemed permissible within the University’s legal framework.
What does this ruling mean for students in disciplinary proceedings at UP?	This ruling highlights that even if a student is acquitted by the SDT, the University President retains the power to review the case, potentially leading to a different outcome based on the President’s assessment of the University’s best interests.
What was the basis for the original complaint against the University Prosecutor?	The original complaint alleged that the University Prosecutor violated professional responsibility and exhibited ignorance of the law by filing a Motion for Partial Reconsideration of the SDT decision, which the complainant argued was impermissible.
How did previous UP Presidents handle similar situations?	Previous UP Presidents, such as President Nemenzo and President Angara, had exercised their power under Article 50 to review SDT decisions, even when appeals were made by parties without an explicit right to appeal.

In conclusion, the Supreme Court’s decision in Maronilla vs. Jorda provides clarity on the extent of the University President’s authority to review SDT decisions within the University of the Philippines system. While this authority is broad, it is not unchecked and must be exercised in accordance with the University Code and principles of due process. The case serves as a reminder of the delicate balance between institutional governance and individual rights within the academic context.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: ROBERT FRANCIS F. MARONILLA, AND ROMMEL F. MARONILLA, COMPLAINANTS, VS. ATTYS. EFREN N. JORDA AND IDA MAY J. LA’O, UP PROSECUTOR AND CHIEF LEGAL OFFICER, UP QUEZON HALL, DILIMAN, QUEZON CITY, RESPONDENTS., A.C. No. 6973, October 30, 2006