SANTIAGO Vs Bautista

SANTIAGO vs. BAUTISTA et al. G.R. No.
L-25024, March 30, 1970

FACTS: Teodoro Santiago, Jr. was a graduating student at Sero Elementary School in Cotabato
City. Prior to the end of the school year, the said school constituted a Committee on the
Rating of Students for Honor composed of teachers of the said school for the purpose of
selecting the honor students of its graduating class. The above-named committee
deliberated and adjudged Teodoro C. Santiago, Jr. as the third honor, the first and second place
being obtained by his two other classmates, Socoro Medina and Patricia Ligat. Three days
before the date of graduation, the third placer Teodoro Santiago, Jr., represented by his
mother and with his father as counsel, sought the invalidation of the ranking of honor
students by instituting an action for certiorari, injunction and damages in the Court of First
Instance of Cotabato against the above-named committee members along with the District
Supervisor and the Academic Supervisor of the place. The complaint alleges grave abuse of
discretions and irregularities in the selection of honor students in the said school such as the
following: (a)the placing of Patricia Ligat in the second place instead of him when in fact he
had been a consistent honor student and the former had never been his close rival before except
in Grade V wherein she ranked third; (b)the tutorial given by their teacher in English to the first
honor during summer vacation; (c)the illegal constitution of the said committee as the same was
composed of all the Grade VI teachers only, in violation of the Service Manual for Teachers of
the Bureau of Public Schools which provides that the committee to select the honor students
should be composed of all teachers in Grades V and VI; (d)the changing of the final ratings on
their grading sheets; (e) that petitioner personally appealed the matter to the School Principal, to
the District Supervisor, and to the Academic Supervisor, but said officials passed the buck to
each other to delay his grievances, and as to appeal to higher authorities will be too late, there
is no other speedy and adequate remedy under the circumstances. Respondents moved for the
dismissal of the case on the grounds (1) that the action for certiorari was improper, and (2) that
even assuming the propriety of the action, the question brought before the court had already
become academic. The motion to dismiss was granted.
ISSUE: Whether or not the action for certiorari filed by petitioner is proper.
RULING: The action for certiorari is not proper. Certiorari is a special civil action instituted
against any tribunal, board, or officer exercising judicial functions (Section 1, Rule 67). A
judicial function is an act performed by virtue of judicial powers; the exercise of a judicial
function is the doing of something in the nature of the action of the court (34 C.J. 1182). In order
that a special civil action of certiorari may be invoked in this jurisdiction the following
circumstances must exist: (1) that there must be a specific controversy involving rights of
persons or property and said controversy is brought before a tribunal, board or officer for hearing
and determination of their respective rights and obligations. It is evident that the so called
committee on the rating of students for honor whose actions are questioned in this case exercised
neither judicial nor quasi judicial functions in the performance of its assigned task. Before
tribunal, board or officer may exercise judicial or quasi judicial acts, it must be clothed with
power and authority to determine what the law is and thereupon adjudicate the respective rights
of the contending parties. In the instant case, there is nothing on record about any rule of law
which provides that when teachers sit down to assess the individual merits of their pupils for
purposes of rating them for honors, such function involves the determination of what the law is
and that they are therefore automatically vested with judicial or quasi judicial functions.

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SANTIAGO vs. BAUTISTA et al. G.R. No.

L-25024, March 30, 1970

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