IT is that time of year again when questions about honors, discipline and school authority come to the fore. One recurring question is this: Can a school validly disqualify an honor student because of a serious offense under the student handbook?
The short answer is yes.
Let me begin with a case I encountered some years ago.
“X,” a Grade 12 graduating student in a private school, committed a serious offense. During school hours and inside the classroom, she attacked a schoolmate, “Y.” Her actions before and after the incident indicated discernment and premeditation. She was already 18 years old at the time. After exhaustive observance of due process, both X and Y were suspended by the school.
The problem arose when the school year was about to end. X was a candidate for honors. Yet because of the serious offense she committed, she was delisted from the honor roll, as expressly provided in the school’s student handbook. She could still graduate, and her grades would remain on record, but she would no longer receive the distinction normally given to students in the honors list during the graduation ceremony.
X’s guardian was informed of the decision. The guardian rejected it. During a series of dialogues with school authorities, teachers and administrators, she threatened, insulted and slandered them. She later continued the attacks on Facebook. Despite this, the teachers and administrators kept their composure. X and her guardian eventually went to the Department of Education’s regional office to file a complaint.
Was the school correct in disqualifying the student from the school’s honor list?
Yes.
Legally speaking, while the relationship between a student and a private school is imbued with public interest, it remains essentially contractual. The right of private schools to promulgate their own rules is recognized by the Department of Education under DepEd Order 88, s. 2010, or the Manual of Regulations for Private Schools in Basic Education. The contract documents include student handbooks, manuals, and other school policies and issuances. So long as these policies are reasonable, fair and properly published, they are legally binding on both the school and its students.
Student X ought to have known her handbook. As a graduating student and candidate for honors, she should have been more circumspect in her actions. Instead, she chose to attack a schoolmate over a personal grudge. She clearly knew what she was doing. She also ought to have known that disciplinary consequences would follow, including removal from the honor roll, as the handbook so provided.
When a student enrolls in a private school, a contract is immediately created. The school-student relationship is reciprocal. It gives rise to bilateral rights and obligations. The school undertakes to provide students with an education sufficient to enable them to pursue higher education or a profession. In turn, students agree to meet the school’s academic requirements and to observe its disciplinary rules and regulations.
Should the student decide to take the matter to court, can the court compel the private school to include her name on the honor roll?
No.
Courts generally respect the academic judgment of educational institutions unless it is blatantly unfair or arbitrary. In landmark jurisprudence, the Supreme Court has held that only when there is marked arbitrariness will courts interfere with the academic judgment of school authorities regarding the competence and fitness of a student. Courts neither have the competence nor the inclination to constitute themselves as admissions or academic review committees and substitute their judgment for that of educational institutions. As the Court memorably warned, if judges were to do so, they would be swamped not only with petitions from those denied admission but also from those who failed and were dropped, all seeking judicial review of grades.
The larger point is simple. Honors are not based on grades alone. They also reflect character, discipline and compliance with standards that schools are entitled to set, so long as these standards are fair, reasonable and clearly communicated. A student cannot invoke academic excellence as a shield against the consequences of serious misconduct.
Schools must, of course, act with fairness, restraint and due process. But once they do, their decisions deserve respect. Discipline is not the enemy of education. It is an essential part of learning.
