Unciano Paramedical College vs. CA

UNCIANO PARAMEDICAL COLLEGE vs. COURT OF APPEALS 221 SCRA 285 (1993) FACTS: Some nursing students were not admitted for the second semester for organizing a student body council which was not allowed by the school which was allegedly a violation of the school regulations. The school argued that under the ALCUAZ DOCTRINE, schools have the discretion to admit students for the second semester because upon enrolment of a student in the first semester, the contract was for that semester only. However a new doctrine was later on promulgated which abandoned the Alcuaz doctrine which is now the NON doctrine.

ISSUE: Whether or not the new Non doctrine be applied retroactively to the case.

HELD: No. The new doctrine shall be applied prospectively and should not apply to parties who relied on the old doctrine and acted on faith thereof.

RELATED NEW CIVIL CODE PROVISION: ARTICLE 4