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The document discusses the case of Kowalski v. Berkeley County Schools, in which a student named Kara Kowalski created a mocking social media group about a classmate. While she created the group at home, the court found the school had jurisdiction to discipline Kowalski because it was reasonably foreseeable her speech would impact the school. The court considered factors like most group members being from her school and it being anticipated the target would see the page. The document examines the extent of schools' jurisdiction over bullying, especially cyberbullying, under the new Anti-Bullying Act of 2013 in the Philippines.
Descrizione originale:
Class requirement for Legal Writing discussing the topic of the Anti-Bullying Act of 2013.
Titolo originale
The Anti-Bullying Act of 2013: School’s Jurisdiction on Bullying Acts Outside Its Premises
The document discusses the case of Kowalski v. Berkeley County Schools, in which a student named Kara Kowalski created a mocking social media group about a classmate. While she created the group at home, the court found the school had jurisdiction to discipline Kowalski because it was reasonably foreseeable her speech would impact the school. The court considered factors like most group members being from her school and it being anticipated the target would see the page. The document examines the extent of schools' jurisdiction over bullying, especially cyberbullying, under the new Anti-Bullying Act of 2013 in the Philippines.
The document discusses the case of Kowalski v. Berkeley County Schools, in which a student named Kara Kowalski created a mocking social media group about a classmate. While she created the group at home, the court found the school had jurisdiction to discipline Kowalski because it was reasonably foreseeable her speech would impact the school. The court considered factors like most group members being from her school and it being anticipated the target would see the page. The document examines the extent of schools' jurisdiction over bullying, especially cyberbullying, under the new Anti-Bullying Act of 2013 in the Philippines.
Schools Jurisdiction on Bullying Acts Outside Its Premises Syed Kamal Reza L. Ampatuan, Arnel Benedict T. Degara, Regina Via G. Garcia, Lourdes Jane N. Mahipus*
ABSTRACT The bullying acts committed by students have been rapidly rampant in schools from various places within our society. The Kowalski case highlights the implementation of punishment by the school of an act committed by the student outside the school premises. These bullying acts were done beyond the ambit of the schools jurisdiction through the use of the internet and in the verge of cyberspace. Despite court attempts and efforts to hold over cases involving the bullying acts committed by these students outside school premises, the schools prerogative to impose disciplinary action and sanction still prevails and remains as the first one to hear over cases regarding harassment and bullying commenced outside the school campus. The question here lies as to what extent does the schools jurisdiction granted by Philippine law have in trying to prevent bullying and how extensive the jurisdiction of schools are given when it comes to bullying acts done outside school premises by electronic means or cyber-bullying.
1. Questions Last September 12, 2013, President Benigno Aquino the third has recently signed into law the Anti-Bullying act which serves to protect school students from abuses made by their fellow classmates. Under Section 3 of the Anti-Bullying Act of 2013 1 : The Law intended to suppress, minimize, or eradicate bullying in schools by directing primary and secondary schools to adopt policies to address the existence of bullying in their respective institutions. The constitution mandates all educational institutions to strengthen ethical and spiritual values, develop moral character and personal discipline. 2 This law is somewhat, a step taken by congress to put into action the principle inlaid in the constitution that mandates all educational institutions to develop moral character and personal discipline. By defining bullying and mandating all schools to curb such actions, the law is a step forward in further strengthening the policy of the state in developing moral character and personal discipline among the youth.
* Legal Writing Students of LLB 1- Viada, College of Law, Ateneo de Davao University
1 Republic Act No. 10627 Anti-Bullying Act (2013)
2 1987 Constitution of the Philippines Article XIV Section 3 (2) 2
The law directs schools to prohibit acts such as bullying inside and outside school if the acts create a hostile environment for the child in school. It also prohibits any retaliation made towards the person who reports bullying and establishes strategies in addressing bullying such as reporting acts of bullying, its investigation, protection of the person who reports the acts from retaliation, counseling towards the victim, perpetrators, and appropriate family members, enabling anonymous reporting, and education of parents and guardians about the nature of bullying, amongst others. The law then provides for sanctions to administrators and schools who shall fail to comply with the requirements under the act. Clearly, the law intends to stop bullying in schools, by requiring schools to follow the requirements provided by the law, and sanctioning those schools and their administrators for non-compliance. One of the most interesting features of the law is its inclusion of cyber-bullying 3 . Thus, the law grants schools jurisdiction over cyber-bullying. This is an important innovation since bullying these days, with its many forms, can now be done through electronic means, such as social networking websites. As later discussed in the case of Kowalski, this form of bullying has a very strong impact upon the lives of young students.
The questions to be addressed then are the following:
1. What extent does the schools jurisdiction have in trying to prevent bullying? 2. How much is the extent of jurisdiction given to schools when it comes to bullying done through electronic means or cyber-bullying? Different cases from other countries as well as from the Philippines that pertain to the issue of bullying will be discussed as well as the Philippine laws that help in answering these questions. Thus, it will be examined how a controversial issue, such as bullying, impacts the lives of different people. Furthermore, this paper will look into where the Philippine laws are lacking compared to Anti-Bullying laws of other countries, as a well as to the reality of bullying and how the law is too limited when it comes to addressing the issue.
2. Kowalski Kowalski was a case filed in the United States Court of Appeals. The petitioner was Kara Kowalski, a student of Berkeley County School District, who created and administered a myspace.com interactive discussion group page, entitled Students against Shays Herpes or S.A.S.H., directed towards a classmate. The discussion group page was created at home, on her home computer, after school hours. The group was used by Kowalski to encourage her classmates to participate in offensive conversations about one of their classmates. The discussion involved Kowalskis classmates who posted defamatory and offensive statements and photo shopped pictures of the targeted student. The parents of the victim filed a harassment complaint with the school upon their discovery of the MySpace page. The school and district took the necessary precautions to investigate the complaint, including interview of Kowalski who admitted to creating the group and page. The schools principal, together with the school board, determined discipline against
3 Anti-Bullying Act of 2013 Section 2 (d) provides:
Cyber-bullying or any bullying done through the use of technology or any electronic means.
3
Kowalski was appropriate because she had created a hate website in violation of school policy and the Student Code of Conduct (CoC) against harassment, bullying, and intimidation. 4
Afterward, Kowalski filed a suit alleging that the school district violated her first amendment right of free speech, and violation of due process, violations of corresponding state laws, and a claim of intentional infliction of emotional distress. Additionally Kowalski sought a declaratory judgment that the School Districts harassment policy was unconstitutionally vague or overbroad and an injunction requiring the school to expunge any record of her discipline. 5
The issue before the United States Court of Appeals was whether or not the first amendment permits a public school to discipline a student for speech that occurs off-campus and not at a school-sponsored event, and that is not directed at the school. The court argued that the law states that a students first amendment rights are not as extensive as an adult 6 , and that public schools have a compelling interest in regulating speech that interferes with or disrupts the work and discipline of the school, including discipline for student harassment and bullying 7 and that schools have a duty to protect their students from harassment and bullying in the school environment 8 . When the petitioner argued that the school districts punishment violated her first amendment rights 9 as her speech took place at home, after school hours, on her home computer and therefore was not within the purview of the schools right to discipline, the court disagreed. When the internet is used as the medium, the court found a sufficient connection between Kowalskis speech and the schools interest in the order, safety and well-being of its students to justify the schools regulation of the speech. The court followed the following factors to come up with the connection 10 : 1. Kowalski knew that the actions taken in her home could reasonably be expected to reach the school or impact the school environment; 2. It was foreseeable that the speech would reach the school; 3. That the dialogue would and did take place among Musselman High School students; 4. That fall out from her conduct and speech would be felt in the school itself;
4 No. 10-1098 (2011)
5 No. 10-1098 (2011)
6 Tinker v. des Moines Indep. Community Sch. Dist. 393 US 503 (1969)
7 No. 10-1098 (2011)
8 No. 10-1098 (2011)
9 The First Amendment of the United States of America provides:
Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the government for a redress of grievances.
5. That the groups name included the word Students; 6. That it was verbally anticipated that the targeted student would see the page; 7. That a vast majority of the group was Musselman High School students, invited by Kowalski.
The court concluded that a school/school board has a compelling interest in regulating student speech that interferes with or disrupts the work and discipline of the school, including discipline for student harassment and bullying and that schools have a duty to protect their students from harassment and bullying in the school environment that outweighs a students rights of free speech, even when exercised away from school.
3. Case Law In the case of De La Salle University, Inc. v. Court of Appeals, 11 it presents a situation where an attack against a student outside the premises of the school. Mr. James Yap went out of the campus using the Engineering Gate to buy candies across Taft Avenue. As he was about to re-cross Taft Avenue, he heard heavy footsteps at his back. Eight to ten guys were running towards him. He panicked. He did not know what to do. Then, respondent Bungubung punched him in the head with something heavy in his hands "parang knuckles." 12 Respondents Reverente and Lee were behind Yap, punching him. Respondents Bungubung and Valdes who were in front of him, were also punching him. As he was lying on the street, respondent Aguilar kicked him. People shouted; guards arrived; and the group of attackers left. Yap later filed a complaint for direct assault to the Discipline Board against his attackers. De La Salle University later on punished its students who were the attackers of Yap.
As stated in the case, the school has an interest in teaching the student, discipline, a necessary, if not indispensible, value in any field of learning. By instilling discipline, the school teaches discipline. Accordingly, the right to discipline the student likewise finds basis in the freedom of what to teach. 13
Therefore, it is within the bounds of the school to sanction their students for unacceptable acts committed outside its premises. This punishment is a form of disciplinary action that helps their student learn their lesson in causing harm to another person.
4. Conundrum
The doctrine in Kowalski, being a foreign case, is inapplicable in Philippine jurisdiction. But it presents the extent of jurisdiction that should be given to schools when it comes to cyber- bullying. The case lets us compare our laws to the jurisprudence laid in the Kowalski. It boils down to the following questions:
11 G.R. No. 127980
12 G.R. No. 127980
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1. How much is the actual jurisdiction given by the anti-bullying law and other existing laws to schools when it comes to bullying? 2. How much jurisdiction is extended to schools by the anti-bullying act when it comes to cyber-bullying? As it has been indicated, it is a principle inlaid in the 1987 Philippine Constitution that all educational institutions must take steps to strengthen ethical and spiritual values, develop moral character and personal discipline. In its duty to discipline students, schools, in Angeles vs. Hon. Sison 14 it was held by the Supreme Court that: A school has the right to investigate, suspend, and/or expel a student for a misconduct committed outside the school premises and beyond school hours if it affects the morale of the school and if it is adverse to the schools order and the students welfare and advancement. This case shows us that the school has jurisdiction over acts committed by the students outside the school premises. This principle is somewhat similar to section 3 (a) (2) of the Anti- Bullying Act of 2013. 15
This provision of the Anti-Bullying Act of 2013 can be compared in the doctrine laid in the Kowalski when it held that schools have compelling interest when it comes to acts of bullying made through the internet that affects order, safety and well-being of students in school and that the school has compelling interest in regulating student speech that interferes with or disrupts the work and discipline of the school. Clearly, Not only does the new law give jurisdiction in prohibiting bullying outside school but also through the use of technology or electronic devise not owned by the school, with the requisite that such acts must create a hostile environment for the victim, infringe his or her rights at school and materially or substantially disrupt his education process.
5. Challenge The New Jersey Anti-Bullying Bill of Rights Act, also known as P.L. 2010, Chapter 122, is a policy created in 2011 by New Jersey legislature to combat bullying in public schools throughout the state. This act is an extension of the states original anti-bullying law, which was first enacted in 2002. Both the New Jersey House of Representatives and the Senate passed the law unanimously in November 2010 and Governor Chris Christie signed the bill on January 5, 2011. The law began to take effect at the beginning of the 2011 school year. Along with both Democratic and Republican legislators, organizations such as Garden State Equality, the Anti-
14 112 SCRA 26 15 The Anti-Bullying Act of 2013 Section 3 (a) (2) provides:
Where the school is given jurisdiction in prohibiting Bullying at a location, activity, function or program that is not school related and through the use of technology or an electronic device that is not owned, leased or used by a school if the act or acts in question create a hostile environment at school for the victim, infringe on the rights of the victim at school, or materially and substantially disrupt the education process or the orderly operation of a school.
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Defamation League of New Jersey 16 , and the New Jersey Coalition for Bullying Awareness and Prevention 17 worked on creating this policy. The Anti-Bullying Bill of Rights provides a strong and thorough definition of bullying. The new bills definition not only describes bullying as a harmful action towards another student, but as any act that infringes on a students rights at school. Congress of New Jersey adopted a definition of school leader and penalty for a student when he commits an act of bullying inside their campus. 18 Any pupil who is guilty of continued and willful disobedience, or of open defiance of the authority of any teacher or person having authority over him, or of the habitual use of profanity or of obscene language, or who shall cut, deface or otherwise injure any school property, shall be liable to punishment and to suspension or expulsion from school. Conduct which shall constitute good cause for suspension or expulsion of a pupil guilty of such conduct shall include, but not be limited to, any of the following:
1. Continued and willful disobedience; 2. Open defiance of the authority of any teacher or person, having authority over him; 3. Conduct of such character as to constitute a continuing danger to the physical well- being of other pupils; 4. Physical assault upon another pupil; 5. Taking, or attempting to take, personal property or money from another pupil, or from his presence, by means of force or fear; 6. Willfully causing, or attempting to cause, substantial damage to school property; 7. Participation in an unauthorized occupancy by any group of pupils or others of any part of any school or other building owned by any school district, and failure to leave such school or other facility promptly after having been directed to do so by the principal or other person then in charge of such building or facility; 8. Incitement which is intended to and does result in unauthorized occupation by any group of pupils or others of any part of a school or other facility owned by any school district; 9. Incitement which is intended to and does result in truancy by other pupils; 10. Knowing possession or knowing consumption without legal authority of alcoholic beverages or controlled dangerous substances on school premises, or being under the influence of intoxicating liquor or controlled dangerous substances while on school premises. 11. Harassment, intimidation, or bullying.
16 http://newjersey.adl.org/
17 http://www.njbullying.org/
18 The New Jersey Anti-Bullying Bill of Rights Act Section 13 provides:
As used in this section, "school leader" means a school district staff member who holds a position that requires the possession of a chief school administrator, principal, or supervisor endorsement. A school leader shall complete training on issues of school ethics, school law, and school governance as part of the professional development for school leaders required pursuant to State Board of Education regulations. Information on the prevention of harassment, intimidation, and bullying shall also be included in the training. The training shall be offered through a collaborative training model as identified by the Commissioner of Education, in consultation with the State Advisory Committee on Professional Development for School Leaders. 7
In the Philippines, the Congress enacted The Anti-Bullying Act of 2013. It became a policy to protect the children who are in elementary and high school level against being bullied by their classmates and schoolmates. The benefits to students are significant as well. When children know that the school they attend actively works to make the learning environment a safe environment, and that bullying is not tolerated, they can let their guard down and focus their attention on learning rather than staying safe. Even students who are not victims or bullies but have witnessed bullying, feel more comfortable and secure knowing that the school community, students, staff and administration stand together against bullying. Congress adopted a definition of acts of bullying, who are liable for the such acts committed by the child. Thus, pertinent sections of the law provide: Section 2. Acts of Bullying. For purposes of this Act, bullying shall refer to any severe or repeated use by one or more students of a written, verbal or electronic expression, or a physical act or gesture, or any combination thereof, directed at another student that has the effect of actually causing or placing the latter in reasonable fear of physical or emotional harm or damage to his property; creating a hostile environment at school for the other student; infringing on the rights of the other student at school; or materially and substantially disrupting the education process or the orderly operation of a school; such as, but not limited to, the following: (a) Any unwanted physical contact between the bully and the victim like punching, pushing, shoving, kicking, slapping, tickling, headlocks, inflicting school pranks, teasing, fighting and the use of available objects as weapons; (b) Any act that causes damage to a victims psyche and/or emotional well-being; (c) Any slanderous statement or accusation that causes the victim undue emotional distress like directing foul language or profanity at the target, name-calling, tormenting and commenting negatively on victims looks, clothes and body; and (d) Cyber-bullying or any bullying done through the use of technology or any electronic means. Section 3. Adoption of Anti-Bullying Policies. All elementary and secondary schools are hereby directed to adopt policies to address the existence of bullying in their respective institutions. Such policies shall be regularly updated and, at a minimum, shall include provisions which prohibit the following acts: A. Prohibit the following acts 1. Bullying on school grounds; property immediately adjacent to school grounds; at school-sponsored or school- related activities, functions or programs whether on or off school grounds; at school bus stops; on school buses or other vehicles 8
owned, leased or used by a school; or through the use of technology or an electronic device owned, leased or used by a school; 2. Bullying at a location, activity, function or program that is not school related and through the use of technology or an electronic device that is not owned, leased or used by a school if the act or acts in question create a hostile environment at school for the victim, infringe on the rights of the victim at school, or materially and substantially disrupt the education process or the orderly operation of a school; and 3. Retaliation against a person who reports bullying, who provides information during an investigation of bullying, or who is a witness to or has reliable information about bullying. As explained earlier about who will be liable for the bullying acts committed by the student inside the school, it is clear that the school should be liable because the child is under their supervision as stated in Article 218 19 and 219 20 or the Family Code of the Philippines. The gist of the argument rises on the issue whether or not the school shall be liable for the bullying acts committed by the student outside the premises of the school because it is known that the bullying act was done beyond the premises of the school. Even though the behavior may have taken place away from school, it could be have an impact on campus. So what course of action can the school officials do? Should they ignore the behavior, discipline the students involved, or look for an alternative way to deal with the problem? The answer isnt obvious. To simplify these two rulings, it could be said that schools must not punish political expression as long as it doesnt lead to disruption, but they can impose sanctions against certain types of lewd speech that go beyond the boundaries of socially appropriate behavior. Based on the ruling, it would seem pretty obvious that schools have the rightsome would say responsibilityto intervene in cases of harassment or cyber-bullying but, the case law refers to activities that took place in campus. These landmark cases were decided long before students
19 Art. 218 of the Family Code of the Philippines provides:
The school, its administrators and teachers, or the individual, entity or institution engaged in child are shall have special parental authority and responsibility over the minor child while under their supervision, instruction or custody. Authority and responsibility shall apply to all authorized activities whether inside or outside the premises of the school, entity or institution. (349a)
20 Art. 219 of the Family Code of the Philippines provides:
Those given the authority and responsibility under the preceding Article shall be principally and solidarily liable for damages caused by the acts or omissions of the unemancipated minor. The parents, judicial guardians or the persons exercising substitute parental authority over said minor shall be subsidiary liable. The respective liabilities of those referred to in the preceding paragraph shall not apply if it is proved that they exercised the proper diligence required under the particular circumstances.
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started using cell phones and internet browsers that allow them to have an easier medium to conduct such acts.
6. Constriction The Supreme Court of United States decided Kowalski that the school has the right to impose penalties when their student committed harassment and bullying acts even though it was outside their premises. However, there are two cases that have an implication on the actions done by the school to sanction a penalty to their students when their acts of harassment and bullying were committed outside the school. A. The first case that presents a contradiction is De la Salle University Inc. v. Court of Appeals 21 . On March 30, 1995, petitioner, Yap, filed a complaint with the Discipline Board of DLSU charging private respondents with direct assault. Later on, the DLSU-CSB Joint Discipline Board issued a Resolution finding private respondents guilty. They were meted the supreme penalty of automatic expulsion. Here, the Supreme Court reversed the decision of the school because the right of due process of the respondents was violated. The Court said: It is true that schools have the power to instill discipline in their students as subsumed in their academic freedom and that "the establishment of rules governing university-student relations, particularly those pertaining to student discipline, may be regarded as vital, not merely to the smooth and efficient operation of the institution, but to its very survival."94 This power, however, does not give them the untrammelled discretion to impose a penalty which is not commensurate with the gravity of the misdeed. If the concept of proportionality between the offense committed and the sanction imposed is not followed, an element of arbitrariness intrudes. That would give rise to a due process question. We agree with respondent CHED that under the circumstances, the penalty of expulsion is grossly disproportionate to the gravity of the acts committed by private respondents Bungubung, Reverente, and Valdes, Jr. Each of the two mauling incidents lasted only for few seconds and the victims did not suffer any serious injury. Disciplinary measures especially where they involve suspension, dismissal or expulsion, cut significantly into the future of a student. They attach to him for life and become a mortgage of his future, hardly redeemable in certain cases. Officials of colleges and universities must be anxious to protect
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it, conscious of the fact that, appropriately construed, a disciplinary action should be treated as an educational tool rather than a punitive measure. The Supreme Court here pointed out that the school cannot impose penalty to their students without proper due process as what Article III Section I of the Constitution stated No person shall be deprived of life, liberty, or property without due process of law, nor shall any person be denied the equal protection of the laws. A formal trial-type hearing is not, at all times and in all instances, essential to due process it is enough that the parties are given a fair and reasonable opportunity to explain their respective sides of the controversy and to present supporting evidence on which a fair decision can be based. "To be heard" does not only mean presentation of testimonial evidence in court one may also be heard through pleadings and where the opportunity to be heard through pleadings is accorded, there is no denial of due process. B. The second case is Gendelman v. Glenbrook North High School. 22 In one Sunday of May 2003, more than 50 students from Glenbrook North High School in Illinois participated in a powder-puff football game at a local forest preserve. At the conclusion of the game, the senior girls held a hazing ritual of the junior girls that included significant violence. Senior girls punched, kicked, hit, and smeared paint and excrement on the junior girls. Some of the junior girls injuries required medical treatment. The district responded by starting suspension and expulsion proceedings s against the senior girls. Most students suspended were seniors who were set to graduate in a few weeks. Two such seniors brought an action in the federal court to enjoin the school district from preventing their graduations. The Northern District of Illinois denied their request for the temporary restraining order. Parenthetically, the discipline was based on a little known school district prohibition against "secret societies" even though everyone in the school, for many years, knew of the event. According to the Court in this case, Courts generally hold that a students interest in extracurricular activities is not constitutionally protected because participation is a privilege to which no property or liberty interest attaches. Accordingly, schools have greater discretion to impose disciplinary consequences to participants in extracurricular activities whose offending conduct occurs off campus. In the case of De La Salle University Inc. v. Court of Appeals, 23 the Court reversed the decision and the penalty imposed by the school to the respondents because according to the Court the school made a violation on the proper due process. However, In the case of Gendelman v. Glenbrook North High School 24 the Court affirm on the decision made by the school to suspend and expel the students who are guilty of harassment and bullying even though off the campus because schools have the right to discipline their students and such penalty imposed is an act of disciplining there students for the acts of harassment and bullying done by their students. Schools have a greater jurisdiction over their students than the courts.
22 LEXIS 8508 (N.D. III. May 21, 2003)
23 G.R. No. 127980
24 LEXIS 8508 (N.D. III. May 21, 2003) 11
The second case has a similarity in the case of Kowalski in terms of the decision made by the Supreme Court of the United States, where in the Court concur to the disciplinary actions made by the school to the respondent. According to latter, the school district violated her first amendment right of free speech, and violation of due process. The Court concluded that a school has the jurisdiction in regulating student speech that disrupts the policy of the school, including discipline for student harassment and bullying and that schools have a duty to protect their students from harassment and bullying in the school environment that outweighs a students rights of free speech, even when exercised away from school.
7. Conclusion The school has jurisdiction over cases involving the bullying acts committed by the students outside school premises and has the power and authority to impose disciplinary measures granted by the Anti-bullying Act. The outside jurisdiction emphasized here involves the cyberspace and speaks of the internet use. Furthermore, jurisdiction means prevention and discipline. The schools ambit of discipline extends to cyber-bullying through computers regardless of the schools ownership and control over the computers. The courts have no jurisdiction unless on administrative matters and if it so happens that the school commits grave abuse of discretion in implementing the policies required by the anti-bullying act, or non- compliance thereof, such matters could result in administrative actions to be filed or complained before the proper authorities such as the Department of Education or the courts. In the of De La Salle University Inc. v. Court of Appeals, 25 the court said that the under the Bill of rights, the school violated due process, however, in the string of cases regarding this matter, the court ruled that the school has the jurisdiction over cases regarding harassment and bullying done even outside the school. Consequently, the school possesses the jurisdiction over the students who committed the bullying acts outside school premises since the school has a significant role in exercising authority and discipline and because students are the persons concerned.
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REFERENCES
Bernas, J. G. (2009). The 1987 Constitution of the Republic of the Philippines: A Commentary. Manila: Rex Book Store. Hanks, J. C. (2004). School Violence: From Discipline to Due Process. Chicago: American Bar Association Publishing. Kowalski v. Berkley County Schools II. Digest. (2011). Retrieved from http://caselaw.findlaw.com/us-4th-circuit/1575495.html Legal Information Institute. (2013). First Amendment. Retrieved from http://www.law.cornell.edu/constitution/first_amendment The New Jersey Anti-Bullying Bill of Rights Act. (2011). Retrieved from http://www.njleg.state.nj.us/2010/Bills/AL10/122_.PDF Official Gazette. (2013). The Anti-Bullying Act of 2013. Retrieved from http://www.gov.ph/2013/09/12/republic-act-no-10627/ Pineda, E. L. (2011). The Family Code of the Philippines Annotated. Quezon City: Central Books Supply, Inc.