The Supreme Court ruled that the University of Santo Tomas (UST) could not simply refuse to release a student’s Transcript of Records (ToR) based on a motion to dismiss. The Court emphasized that when a valid cause of action exists, a full trial is necessary to uncover all relevant facts, especially when resolving the case depends on evidence appreciation. This decision underscores the importance of due process and the right of students to access their academic records, ensuring schools cannot arbitrarily withhold these documents.

The Case of the Delayed Transcript: Can Schools Unilaterally Withhold Academic Records?

This case revolves around Danes B. Sanchez, a graduate of the University of Santo Tomas (UST) who was denied his Transcript of Records (ToR). Sanchez filed a complaint for damages against UST, alleging that their refusal to release his ToR prevented him from taking the nursing board examinations and earning a living. UST countered that Sanchez was not a registered student because he had not enrolled for the last three semesters before graduation, seeking dismissal of the case. The central legal question is whether UST’s refusal was justified and whether Sanchez was entitled to damages for the delay.

The petitioners, UST, argued that the Commission on Higher Education (CHED) had primary jurisdiction over the matter and that Sanchez had failed to exhaust administrative remedies by initially seeking recourse from CHED. The Court addressed this argument by clarifying that the doctrine of exhaustion of administrative remedies does not apply when the issues are purely legal and within the jurisdiction of the trial court. The Supreme Court emphasized that the CHED’s mandate does not extend to awarding damages, which is a judicial function. The Court, quoting Regino v. Pangasinan Colleges of Science and Technology, stated:

x x x exhaustion of administrative remedies is applicable when there is competence on the part of the administrative body to act upon the matter complained of. Administrative agencies are not courts; x x x neither [are they] part of the judicial system, [or] deemed judicial tribunals. Specifically, the CHED does not have the power to award damages. Hence, petitioner could not have commenced her case before the Commission. (Emphasis ours)

Building on this principle, the Supreme Court noted that the CHED lacks the quasi-judicial power required to adjudicate the case fully. Quasi-judicial power involves the ability to investigate facts, hold hearings, weigh evidence, and draw conclusions—powers not explicitly granted to the CHED under Republic Act No. 7722, also known as the Higher Education Act of 1994. Consequently, the Court found that the CHED’s involvement did not preclude the trial court from hearing the case.

Furthermore, UST claimed that Sanchez was guilty of forum shopping because he sought recourse from both the CHED and the RTC. However, the Court dismissed this argument, explaining that forum shopping occurs when a party seeks a favorable opinion in another forum after receiving an adverse opinion in one, or when multiple actions are instituted based on the same cause of action. Since the CHED lacks quasi-judicial power and cannot make a binding disposition, there could be no forum shopping in this instance. The Supreme Court cited Cabarrus, Jr. v. Bernas, stating:

The courts, tribunal and agencies referred to under Circular No. 28-91, revised Circular No. 28-91 and Administrative Circular No. 04-94 are those vested with judicial powers or quasi-judicial powers and those who not only hear and determine controversies between adverse parties, but to make binding orders or judgments. As succinctly put by R.A. 157, the NBI is not performing judicial or quasi-judicial functions. The NBI cannot therefore be among those forums contemplated by the Circular that can entertain an action or proceeding, or even grant any relief, declaratory or otherwise.

The Court then addressed the argument that Sanchez’s complaint failed to state a cause of action. UST contended that Sanchez admitted he was not officially enrolled in the last three semesters before graduation. The Supreme Court clarified that a motion to dismiss on the ground that the pleading asserting the claim states no cause of action can only be sustained if, admitting the facts alleged, the court could not render a valid judgment in accordance with the prayer of the petition. The Court found that Sanchez’s complaint made essential allegations, including that UST unjustifiably refused to release his ToR, preventing him from taking the nursing board exams, and that these actions violated Articles 19-21 of the Civil Code. Therefore, assuming the facts were true, the RTC could render a valid judgment.

The Court found that paragraph 10 of the Complaint, cited by UST, did not constitute an admission by Sanchez that he was not enrolled. Instead, any allegation concerning the use of force or intimidation by UST could strengthen Sanchez’s complaint for damages. The Supreme Court agreed with the RTC’s finding that a resolution of the case required the presentation of evidence during trial. Several factual matters needed to be settled, including whether Sanchez was enrolled, whether his degree was obtained fraudulently, and whether there was fault or negligence on the part of any of the parties. The Court determined that these issues could be best ventilated in a full-blown proceeding before the trial court.

The Court also clarified that while Section 33 of the Manual of Regulations of Private Schools authorizes the CHED to cancel or revoke the graduation of any student whose records are found to be fraudulent, this provision did not apply because the CHED had not taken any action to revoke Sanchez’s graduation. Additionally, Section 72 of the same manual, which permits schools to withhold credentials due to suspension, expulsion, or non-payment of financial obligations, was also inapplicable as none of these circumstances were present.

Building upon the analysis of the regulations, the Supreme Court emphasized the need for a thorough examination of the evidence. The case hinges on whether UST acted justifiably in withholding Sanchez’s ToR. If UST’s actions were proven to be negligent or in bad faith, Sanchez would be entitled to damages under Articles 19-21 of the Civil Code, which address abuse of rights, acts contrary to law, and acts contrary to morals. The presentation of evidence would allow the trial court to assess the credibility of both parties and determine the extent of any damages suffered by Sanchez.

The practical implications of this ruling are significant for students and educational institutions. The Supreme Court reaffirmed that schools cannot arbitrarily withhold academic records without due process. Students have the right to access their ToRs to pursue further education or employment opportunities, and schools must have a legitimate and justifiable reason for any refusal. The decision underscores the importance of protecting students’ rights and ensuring that educational institutions act responsibly and in accordance with the law.

Furthermore, this case serves as a reminder to schools that they must follow proper procedures and provide a clear and transparent explanation for withholding a student’s records. Schools must also be prepared to substantiate their claims with evidence and allow for a fair hearing of the matter. This ruling promotes accountability and fairness in the relationship between educational institutions and their students, ensuring that students are not unfairly disadvantaged by administrative actions.

FAQs

What was the key issue in this case?	The key issue was whether the University of Santo Tomas (UST) was justified in refusing to release Danes B. Sanchez’s Transcript of Records (ToR). The case examined the grounds for withholding academic records and the student’s right to access them.
Did the Supreme Court find UST’s refusal to release the ToR justified?	No, the Supreme Court did not find UST’s refusal justified and directed the Regional Trial Court (RTC) to proceed with a full trial. The Court emphasized that a full trial was necessary to unearth all relevant facts and circumstances.
What is the doctrine of exhaustion of administrative remedies, and does it apply here?	The doctrine requires that remedies before an administrative agency must be exhausted before an action is brought before the courts. The Court ruled it did not apply because the CHED lacked the power to award damages, a central aspect of Sanchez’s complaint.
What is forum shopping, and was Sanchez guilty of it?	Forum shopping is seeking a favorable opinion in another forum after an adverse one or instituting multiple actions on the same cause. Sanchez was not guilty because the CHED lacks quasi-judicial power to make a binding disposition.
What are the essential elements of a cause of action?	The elements include a right in favor of the plaintiff, an obligation on the defendant to respect that right, and an act or omission by the defendant violating the plaintiff’s right. All these elements must be present for a complaint to state a valid cause of action.
Did the Court find that Sanchez’s complaint stated a cause of action?	Yes, the Court found that Sanchez’s complaint stated a cause of action because it alleged that UST unjustifiably refused to release his ToR, preventing him from taking the nursing board exams. These allegations, if true, would entitle Sanchez to relief.
What is quasi-judicial power, and does the CHED possess it?	Quasi-judicial power is the authority to investigate facts, hold hearings, weigh evidence, and draw conclusions. The Court found that the CHED does not possess such power concerning the matters in this case.
What is the significance of Articles 19-21 of the Civil Code in this case?	Articles 19-21 address abuse of rights, acts contrary to law, and acts contrary to morals. Sanchez alleged that UST’s actions violated these articles, which could entitle him to damages if proven.
Can schools withhold a student’s credentials for any reason?	No, schools can only withhold credentials for specific reasons like suspension, expulsion, or non-payment of financial obligations. The Court noted that none of these circumstances were present in Sanchez’s case.

In conclusion, the Supreme Court’s decision in this case reinforces the importance of due process and fairness in the relationship between educational institutions and their students. It clarifies the limits of a school’s authority to withhold academic records and underscores the student’s right to access these documents for their educational and professional pursuits. The Court’s emphasis on a full trial to uncover all relevant facts ensures that cases involving the unjustified refusal to release academic records are thoroughly examined and justly resolved.

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: UNIVERSITY OF SANTO TOMAS vs. DANES B. SANCHEZ, G.R. No. 165569, July 29, 2010