G.R. No. L-45157. June 27, 1985 (Case Brief - Digest)

G.R. No. L-45157.
June 27, 1985 (Case Brief / Digest)
### Title:
**Tangonan vs. Hon. Judge Ernani Cruz Paño et al., G.R. No. L-47226, 221 Phil. 601
(1979)**
### Facts:
1. **Admission on Probation:** Mely Tangonan was admitted on a probationary basis in May
1975 at Capitol Medical Center School of Nursing for the school year 1975-1976,
conditional on providing a sealed “Honorable Dismissal” and a “Transcript of Records” valid
for transfer. She submitted unsealed versions, promising immediate replacement with
official records.
2. **Academic Difficulties:** Tangonan completed the first semester but failed Psychiatric
Nursing in the second semester. She cross-enrolled for the subject at De Ocampo Memorial
School during the Summer of 1976 but attempted to bribe Dean Florencia Pagador for her
name to be included among enrolled students, which she acknowledged in a letter of
apology.
3. **Re-enrollment Issues:** In June 1976, Tangonan applied for re-enrollment at Capitol

Medical Center School of Nursing (CMCSN) but was asked to address issues pertinent to
her academic records and the bribery charge. Her reluctance to submit the required
explanations led the Board of Admission to declare her an undesirable student on June 25,
1976.
4. **Administrative Remedy:** Tangonan sought intervention from the Department of

Education, where she agreed to transfer to another school during a mediation conference
but later filed a petition for mandamus in the Court of First Instance of Rizal.
5. **Lower Court Proceedings:**

– The lower court issued a preliminary mandatory injunction on July 27, 1977, leading to
Tangonan’s temporary admission.
– Respondents filed defenses highlighting Tangonan’s agreement to transfer and the
school’s right to refuse admission based on academic and behavioral grounds.
– The court determined the issue was solely legal and required submission of memoranda
and pertinent documents instead of formal hearings.
– On October 22, 1976, the court dismissed the petition, lifting the preliminary injunction.
### Issues:
1. **Grave Abuse of Discretion:** Whether the trial judge exhibited grave abuse of
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G.R. No. L-45157. June 27, 1985 (Case Brief / Digest)
discretion by deciding without a formal hearing.

2. **Mandamus Applicability:** Whether mandamus is an appropriate remedy for a student
refused re-enrollment due to alleged academic and behavioral deficiencies and exclusion
from enrolling while others were allowed.
3. **Conformity with Law and Evidence:** Whether the lower court’s decision aligns with
applicable law and evidence presented.
### Court’s Decision:

**Issue 1: Grave Abuse of Discretion**
– **Ruling:** The Supreme Court ruled no grave abuse of discretion occurred. Expedient
resolution methods (submission of affidavits and memoranda) were appropriate for the
nature of the mandamus petition, which primarily involved legal questions rather than
factual ones. Petitioner participated in this expedited process without objection, thus is
estopped from later challenging it.
**Issue 2: Mandamus Applicability**

– **Ruling:** Mandamus was deemed inappropriate. The duty to admit a student involves
discretion, not merely a ministerial act. Petitioner’s academic shortcomings, incomplete
documentation, and behavioral issues (specifically the bribery attempt) fell under valid
grounds for non-reenrollment. The school’s authority to determine student fitness,
especially in a sensitive profession like nursing, constituted the exercise of academic
freedom under Article XV, Section 8, Paragraph 2 of the 1973 Constitution.
**Issue 3: Conformity with Law and Evidence**

– **Ruling:** The lower court’s decision was consistent with prevailing legal standards and
supported by substantial evidence. Tangonan’s own acknowledgment of misconduct and
academic deficiencies justified the school’s decision. The school’s refusal was aligned with
Section 107 of the Manual Regulations for Private Schools, validating academic delinquency
and disciplinary violations as grounds for re-enrollment denial.
### Doctrine:
The case reinforces the principle that mandamus cannot compel discretionary acts and
emphasizes academic freedom for educational institutions, especially regarding admissions
and maintaining standards for professional competencies.
### Class Notes:

1. **Mandamus Conditions:** Per Rule 65, Section 3 of the Rules of Court, the writ applies
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G.R. No. L-45157. June 27, 1985 (Case Brief / Digest)
to compel performance of a ministerial duty, not discretionary actions.

2. **Academic Freedom:** Schools possess the autonomy to establish admission standards
and make discretionary decisions regarding student fitness without external coercion unless
public welfare mandates otherwise.
3. **Section 107 of the Manual Regulations for Private Schools:** Academic delinquency and
disciplinary violations justify non-reenrollment.
### Historical Background:

At the time of the decision, the Philippines was under Martial Law and a new constitution
was in effect, emphasizing academic freedom (1973 Constitution, Article XV, Section 8).
Nursing’s high demand internationally, particularly for Filipino professionals, underscored
the importance of rigorous academic and behavioral standards in nursing education
institutions.
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G.R. No. L-45157.

June 27, 1985 (Case Brief / Digest)

3. Re-enrollment Issues: In June 1976, Tangonan applied for re-enrollment at Capitol

4. Administrative Remedy: Tangonan sought intervention from the Department of

5. Lower Court Proceedings:

discretion by deciding without a formal hearing.

### Court’s Decision:

Issue 2: Mandamus Applicability

Issue 3: Conformity with Law and Evidence

### Class Notes:

to compel performance of a ministerial duty, not discretionary actions.

### Historical Background:

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