The Supreme Court ruled that schools cannot impose new fees on students after they have already enrolled for the semester. This decision protects students from unexpected financial burdens and ensures that the terms of their enrollment contract remain consistent throughout the academic period. The Court emphasized that education is a right, and schools must respect the terms agreed upon at the time of enrollment.

Fundraising or Coercion?: The Case of the Compulsory Rave Party Tickets

Khristine Rea M. Regino, a computer science student at Pangasinan Colleges of Science and Technology (PCST), faced a predicament when the school launched a fundraising campaign mid-semester. Students were required to purchase tickets for a “Rave Party and Dance Revolution” to fund the construction of tennis and volleyball courts. Khristine, unable to afford the tickets and prohibited by her religion from attending such events, refused to pay. Consequently, she was allegedly barred from taking her final examinations in logic and statistics, leading her to file a complaint for damages against PCST and her teachers.

The central legal question revolves around whether PCST could enforce this mandatory fee after Khristine had already enrolled. The trial court dismissed the case, arguing that the Commission on Higher Education (CHED) had jurisdiction over the matter. However, the Supreme Court disagreed, emphasizing the importance of the contract between the school and its students. The Court looked at two critical issues: the application of the doctrine of exhaustion of administrative remedies and the sufficiency of the causes of action stated in the complaint.

Building on established jurisprudence, the Court reiterated that when a student enrolls, a reciprocal contract is formed. This contract obligates the school to provide education, while the student agrees to abide by academic standards and school regulations. Crucially, the terms of this contract are set at the time of enrollment, and the school cannot unilaterally alter them mid-semester. The Court has previously established that a higher learning institution has a contractual obligation to afford its students a fair opportunity to complete their course of study, provided they meet academic standards and comply with school rules.

According to the Court, requiring students to purchase tickets for a fundraising event as a prerequisite for taking final examinations constituted a breach of this contract. Furthermore, this action potentially gave rise to tort liability under Articles 19, 21, and 26 of the Civil Code. These articles concern the principles of acting with justice, compensating for damages caused by actions contrary to morals or public policy, and respecting the dignity of others.

Article 19 states:

“Every person must, in the exercise of his rights and in the performance of his duties, act with justice, give everyone his due, and observe honesty and good faith.”

The Supreme Court also distinguished this case from Crystal v. Cebu International School, where the Court upheld a “land purchase deposit” because it was imposed after prior consultation and approval by the parents of the students.

The Court clarified that even though academic institutions have academic freedom to determine who to admit and what to teach, these freedoms should not be used to discriminate against students or breach contractual obligations. Once a student is admitted, the school must honor the terms of the enrollment contract. Also, the school’s action did not align with academic freedom principles since it introduced a financial burden post-enrollment and created conditions to prohibit final exams.

Furthermore, it considered whether administrative remedies needed to be exhausted before court intervention. Since Khristine was claiming damages, a remedy beyond CHED’s power to grant, the Court determined it was unnecessary to exhaust administrative remedies. Exhaustion of administrative remedies is not required when the issue is purely legal and within the court’s jurisdiction. The Supreme Court highlighted that it was crucial for laws in the Civil Code to be applied and interpreted, something within the judicial purview. Thus, the Supreme Court granted the Petition and directed the trial court to reinstate the Complaint and proceed with the case.

FAQs

What was the key issue in this case?	The key issue was whether a school could require students to pay for fundraising tickets as a condition for taking final examinations after the students had already enrolled.
Did the Supreme Court side with the student or the school?	The Supreme Court sided with the student, Khristine Rea M. Regino, holding that the school’s actions were a breach of contract and could potentially give rise to tort liability.
What is the school-student contract?	The school-student contract refers to the reciprocal agreement formed when a student enrolls in a school, where the school provides education and the student agrees to abide by academic standards and school regulations.
Can schools change the terms of enrollment after a student has enrolled?	No, schools cannot unilaterally change the terms of enrollment after a student has enrolled, as the terms are set at the time of enrollment and form the basis of the school-student contract.
Does the Commission on Higher Education (CHED) have the power to award damages?	No, the CHED does not have the power to award damages, which is why the Supreme Court ruled that the student did not need to exhaust administrative remedies before going to court.
What is academic freedom?	Academic freedom encompasses the independence of an academic institution to determine who may teach, what may be taught, how it shall teach, and who may be admitted to study.
Can academic freedom be used to discriminate against students?	No, academic freedom cannot be used to discriminate against students or breach contractual obligations that the school has with its students upon enrollment.
What happens if a school breaches its contract with a student?	If a school breaches its contract with a student, it may be held liable for damages, including moral and exemplary damages, as well as actual damages and attorney’s fees.
Why does this case matter?	This case matters because it reinforces the importance of the school-student contract, protects students from unexpected fees, and clarifies the limits of academic freedom in relation to students’ rights.

In conclusion, the Supreme Court’s decision in this case underscores the significance of upholding contractual agreements in the educational context. It serves as a reminder that schools must act fairly and transparently in their dealings with students, and it emphasizes the importance of respecting the rights and dignity of all individuals, regardless of their economic circumstances or religious beliefs. This ruling provides important guidance for students and institutions alike.

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: Regino v. PCST, G.R. No. 156109, November 18, 2004