Santiago vs. Bautista

A committee of public school teachers constituted to rate and select honor students does not exercise judicial or quasi-judicial functions within the meaning of Rule 65, and certiorari does not lie against it; moreover, failure to accompany a petition for certiorari with a certified true copy of the judgment or order complained of, together with copies of all relevant pleadings and documents, is fatal to the petition.

Teodoro C. Santiago, Jr. was a Grade Six pupil at Sero Elementary School in Cotabato City, nearing graduation for the school year 1964–1965. The school constituted a "Committee on the Rating of Students for Honor" composed of Grade VI teachers and headed by the school principal to select the graduating class's honor students. The selection of honor pupils in public schools was governed by the Service Manual for Teachers of the Bureau of Public Schools, which prescribed the composition and procedure of such committees. Santiago's father acted as his counsel in the litigation, while his mother represented him as a minor.

As the school year 1964–1965 drew to a close, Sero Elementary School in Cotabato City constituted a "Committee on the Rating of Students for Honor" to select the honor students of its graduating Grade Six class. The committee was chaired by school principal Mrs. Aurora Lorena and included teachers Juanita Bautista, Rosalinda Alpas, Rebecca Matugas, Milkita Inamac, Romeo Agustin, Aida Camino, and Luna Sarmago as members. After deliberation, the committee adjudged Socorro Medina, Patricia Liñgat, and Teodoro C. Santiago, Jr. as first, second, and third honors, respectively. The graduation exercises were set for May 21, 1965.

Three days before graduation, on May 18, 1965, Santiago, represented by his mother and with his father as counsel, filed a complaint for certiorari, injunction, and damages in the Court of First Instance of Cotabato against the committee members, the District Supervisor, and the Academic Supervisor. The complaint alleged that Santiago had been a consistent honor pupil from Grade I to Grade V, while Patricia Liñgat had never been a close rival except in Grade V where she ranked third. It charged that Socorro Medina had been coached and tutored during the summer vacation of 1964 by Mrs. Alpas, who later became the English teacher of both Medina and Santiago in Grade VI, giving Medina an unfair advantage. The complaint further alleged that the committee was illegally constituted because it was composed solely of Grade VI teachers, in violation of the Service Manual for Teachers, which required the committee to include teachers from Grades V and VI. Other irregularities were cited, including the changing of final ratings of Medina and Liñgat from 80% to 85%, the giving of district examinations outside of standard periodical tests, the awarding of a perfect score to Medina described as "very unnatural," and the erasure of "first place" on Santiago's Grade I certificate, replaced with "second place." Santiago claimed to have personally appealed to the school principal, the district supervisor, and the academic supervisor, who "passed the buck to each other." He sought to set aside the final list of honor students and to enjoin the proclamation of the honor pupils during the graduation exercises, and demanded P10,000 in moral and mental damages.

The lower court denied the injunction on May 20, 1965, reasoning that the graduation exercises were set for the following day and a restraining order would be disruptive. The graduation proceeded as scheduled on May 21, 1965, with the protested list of honor students. Respondents moved to dismiss the petition on May 24, 1965, arguing that the action for certiorari was improper and that the question had become academic. On June 4, 1965, the lower court granted the motion to dismiss, finding that the petition failed to comply with the second paragraph of Section 1, Rule 65 (no certified true copy of the judgment or order complained of was attached), that administrative remedies had not been exhausted, and that the allegations showed mere errors or irregularities rather than grave abuse of discretion amounting to lack of jurisdiction. Santiago's motion for reconsideration was denied, prompting the present appeal.

• Compliance with Rule 65: Petitioner assailed the lower court's holding that his failure to attach a certified true copy of the judgment or order complained of was fatal, noting that he received a copy of the graduation programme only on the morning of the graduation exercises themselves, making it impossible to attach such document to the petition filed earlier.
• Exhaustion of Administrative Remedies: Petitioner contended that he had personally appealed to the school principal, the district supervisor, and the academic supervisor, who merely "passed the buck to each other," and that an appeal to higher authorities would be too late given the impending graduation.
• Grave Abuse of Discretion: Petitioner maintained that the allegations in his complaint — illegal composition of the committee, alteration of ratings, tutoring of a rival by a committee member, and erasure of his Grade I certificate — constituted grave abuse of discretion on the part of the respondent teachers, not mere errors.

• Not a Judicial or Quasi-Judicial Body: Respondents argued that the "Committee on the Rating of Students for Honor" is not a "tribunal, board, or officer exercising judicial functions" against which certiorari may lie under Section 1 of Rule 65.
• Improper Remedy and Mootness: Respondents maintained that the action for certiorari was improper and that the question had already become academic since the graduation exercises had already been held.
• No Grave Abuse of Discretion: Respondents contended that the allegations in the petition referred to errors, mistakes, or irregularities rather than to grave abuse of discretion amounting to lack of jurisdiction correctible by certiorari.

• Nature of the Committee's Function: Whether the committee of teachers constituted to rate and select honor students exercises judicial or quasi-judicial functions within the meaning of Rule 65 so as to be a proper respondent in a petition for certiorari.
• Compliance with Documentary Requirements: Whether the petitioner's failure to accompany his petition with a certified true copy of the judgment or order complained of and copies of all relevant pleadings and documents, as required by the second paragraph of Section 1, Rule 65, is fatal to the petition.
• Exhaustion of Administrative Remedies: Whether the petitioner was required to exhaust administrative remedies within the Department of Education before resorting to certiorari.
• Grave Abuse of Discretion: Whether the allegations in the petition constitute grave abuse of discretion amounting to lack of jurisdiction, or merely errors and irregularities not correctible by certiorari.

• Nature of the Committee's Function: No. The committee of teachers that rates students for honors exercises neither judicial nor quasi-judicial functions, because there is no rule of law that vests such a committee with authority to determine legal rights of parties in a controversy in the adjudicatory sense required by Rule 65.
• Compliance with Documentary Requirements: Yes, the failure is fatal. The second paragraph of Section 1, Rule 65 requires the petition to be accompanied by a certified true copy of the judgment or order subject thereof and copies of all relevant pleadings and documents; non-compliance renders the petition indefinite and uncertain.
• Exhaustion of Administrative Remedies: Affirmed as an additional ground. The allegation that school authorities "passed the buck to each other" does not show formal exhaustion of administrative remedies within the Department of Education.
• Grave Abuse of Discretion: No. The allegations refer to errors, mistakes, or irregularities rather than grave abuse of discretion amounting to lack of jurisdiction correctible by certiorari.

• Nature of the Committee's Function: The Court applied a three-part test drawn from jurisprudence to determine whether a body exercises judicial or quasi-judicial functions: (1) there must be a specific controversy involving rights of persons or property brought before a tribunal, board, or officer for hearing and determination; (2) the tribunal must have the power and authority to pronounce judgment and render a decision construing and applying the laws; and (3) the tribunal must pertain to the judiciary or at least not belong to the legislative or executive department. The Court found that no rule of law provides that when teachers assess pupils' merits for honors, such function involves the determination of what the law is or the adjudication of legal rights in a controversy. The nature of the act, not the office performing it, determines whether the function is judicial. The committee's task of rating students for honors is administrative or ministerial in character, not adjudicatory. The Court drew a parallel to Felipe vs. Leuterio, where it held that the judiciary has no power to reverse the award of a board of judges in an oratorical contest, reasoning that contestants have no right to a prize until declared winners by the appointed judges, and that errors in such competitions do not constitute legal wrongs actionable in court.

• Compliance with Documentary Requirements: The Court found that the petitioner had known of the committee's decision well before filing his petition, as evidenced by his own statement that he had personally appealed to various school authorities before filing the case on May 19, 1965. Moreover, the petition mentioned several documents — the Service Manual for Teachers allegedly violated, altered grading sheets, and erasures in his Grade I certificate — none of which were attached. Citing Alajar vs. Court of Industrial Relations and NAWASA vs. Municipality of Libmanan, the Court held that failure to attach the required documents is fatal to a petition for certiorari, rendering it patently insufficient in form and substance.

• Exhaustion of Administrative Remedies: The Court agreed with the lower court that the allegation of having "passed the buck to each other" does not demonstrate formal exhaustion of administrative remedies. The administrative agencies of the Department of Education could have investigated the grievances with dispatch, but petitioner negligently abandoned them.

• Grave Abuse of Discretion: The Court concurred with the lower court that the allegations relating to "grave abuse of discretion" refer to errors, mistakes, or irregularities rather than to real grave abuse of discretion amounting to lack of jurisdiction. Mere commission of errors in the exercise of jurisdiction may not be corrected by certiorari.

• Nature of Judicial or Quasi-Judicial Functions — A function is judicial or quasi-judicial only when there exists a law giving rise to specific rights of persons or property, adverse claims to such rights are made, and the controversy is brought before a tribunal clothed with power and authority to determine what the law is and adjudicate the respective rights of the contending parties. It is the nature of the act performed, not the character of the office or body performing it, that determines whether the function is judicial. The exercise of discretion and judgment alone does not make a function judicial; it must pertain to the judiciary or at least not belong to the legislative or executive department. In this case, the Court applied this test and held that a committee of teachers selecting honor students does not exercise judicial or quasi-judicial functions.

• Finality of Judges' Awards in Competitions — In competitions such as oratorical contests, beauty contests, and similar competitions, the board's decision is final and unappealable. Contestants have no right to the prize unless and until declared winners by the appointed judges. Error and wrong do not mean the same thing; "wrong" is the deprivation or violation of a right, and a contestant has no right to a prize until proclaimed winner. Absent fraud or malice, a loss in such a competition is a case of damnum absque injuria. The Court applied this doctrine by analogy to the selection of honor students.

• Documentary Requirements of Certiorari under Rule 65 — The petition for certiorari must be accompanied by a certified true copy of the judgment or order subject thereof, together with copies of all pleadings and documents relevant and pertinent thereto. Failure to comply renders the petition indefinite and uncertain and is fatal to the cause. The Court applied this requirement strictly, noting that petitioner had known of the committee's decision well before filing and had mentioned several documents in his petition without attaching any of them.

• "It is evident, upon the foregoing authorities, 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." — This is the ratio decidendi on the first issue, establishing that a teachers' honor-selection committee is not a proper respondent in certiorari because it does not adjudicate legal rights.

• "No rights to the prizes may be asserted by the contestants, because theirs was merely the privilege to compete for the prize, and that privilege did not ripen into a demandable right unless and until they were proclaimed winners of the competition by the appointed arbiters or referees or judges." — This passage from Felipe vs. Leuterio, quoted and relied upon by the Court, articulates the doctrine that competition results are final and not subject to judicial review absent fraud or malice.

• "The stubborn fact remains, however, that appellant had known of such decision of the said committee of teachers much earlier, as shown by the circumstance that according to him, even before the filing of his petition with the lower court on the 19th of May, 1965, he had personally appealed the said committee's decision with various higher authorities of the above-named school, who merely passed the buck to each other." — This passage underscores the Court's rejection of petitioner's excuse for non-compliance with the documentary requirements of Rule 65.

• Felipe vs. Leuterio, et al., 91 Phil. 482 (1952) — Controlling precedent followed by analogy. The Court held that the judiciary has no power to reverse the award of a board of judges in an oratorical contest, and that contestants have no right to a prize until declared winners. The Court applied the same reasoning to the selection of honor students.
• Alajar vs. Court of Industrial Relations, G.R. Nos. L-8174 and L-8280-86, October 8, 1955, 97 Phil. 675 — Followed. The Court dismissed a petition for certiorari for failure to attach copies of the decisions allegedly violated, establishing the principle that non-compliance with the documentary requirements of Rule 65 is fatal.
• NAWASA vs. Municipality of Libmanan, et al., L-27197, May 31, 1967, 20 SCRA 337 — Followed. The Court dismissed a petition for certiorari and mandamus for failure to attach copies of the complaint, decision, order of default, and record on appeal, reinforcing the strict documentary requirements of Rule 65.
• Municipal Council of Lemery vs. Provincial Board of Batangas, 56 Phil. 260 — Cited for the proposition that it is the nature of the act to be performed, rather than the office or body performing it, that determines whether the function is judicial or quasi-judicial.

• Section 1, Rule 65, Rules of Court — Governs the special civil action of certiorari, available when any tribunal, board, or officer exercising judicial functions has acted without or in excess of jurisdiction or with grave abuse of discretion, and there is no appeal or plain, speedy, and adequate remedy in the ordinary course of law. The second paragraph requires the petition to be accompanied by a certified true copy of the judgment or order subject thereof, together with copies of all relevant pleadings and documents. The Court applied both the jurisdictional requirement (the committee was not exercising judicial functions) and the documentary requirement (petitioner failed to attach required documents) to affirm dismissal.

Concepcion, C.J., Reyes, J.B.L., Dizon, Makalintal, Zaldivar, Castro, Fernando, Teehankee, and Villamor, JJ., concurred.