Lina v. Purisima
REITERATIONFacts
The Antecedents: The petitioner, Lualhati L. Lina, was dismissed from her position at the Philippine Veterans Bank. The dismissal was based on recommendations from her branch manager and subsequently approved by the Bank's President, Esteban Cabanos, and the Board of Directors. The petitioner appealed her dismissal to the Office of the President, but this appeal was denied. The dismissal was later clarified to be pursuant to Letters of Instruction No. 14 and No. 19-A, for being notoriously undesirable. Procedural History: The petitioner filed a complaint in the Court of First Instance of Manila, seeking reinstatement and damages. The respondent judge issued two successive orders dismissing the case, first for lack of jurisdiction and then for the reason that the relief sought was beyond the court's power to grant, citing General Order No. 3. The petitioner then elevated the matter to the Supreme Court via a petition for certiorari and mandamus. The Petition: The petitioner sought a writ of certiorari and mandamus to annul the dismissal orders of the Court of First Instance and to compel the respondent judge to try the case on its merits. The Supreme Court, in its decision, found the respondent court's reliance on General Order No. 3 to be an unwarranted abdication of judicial authority. While the Court found the dismissal orders erroneous, it also noted that the respondents had subsequently issued Administrative Order No. 6, reinstating the petitioner to her former position and agreeing to pay back salaries, allowances, and expenses. The Supreme Court, therefore, deemed the case terminated based on these developments, ruling that the petitioner was not entitled to moral and exemplary damages due to her failure to report for work promptly after the reinstatement offer, but was entitled to back salaries and expenses as agreed upon by the respondents.
Issue(s)
Whether the respondent court committed a grave abuse of discretion in dismissing the petition for certiorari and mandamus on the ground that the validity of acts done pursuant to Proclamation No. 1081 was beyond its power to review. Whether the Supreme Court, in the interest of substantial justice, can resolve the case on the merits despite the procedural issues, given that all necessary facts are before it and the parties have submitted the matter for resolution.
Ruling
The Supreme Court declared the respondent court's order of September 3, 1974, null and void and set it aside. The case was deemed terminated in accordance with the terms of the decision. The Court ruled that petitioner should report for work within thirty (30) days from service of the decision upon her counsel, on pain of losing her job. Respondents' tender of back salaries and expenses was declared well-taken, and petitioner was to be paid her back salaries from October 16, 1972, up to thirty (30) days after her counsel's receipt of the respondents' Manifestation and Comment of November 12, 1976, and reimbursement of actual expenses, including attorney's fees equivalent to ten (10) percentum of the total recovery.
Ratio Decidendi
On Issue 1: The Supreme Court held that the respondent court's invocation of General Order No. 3 as a basis for dismissing the petition was an unwarranted abdication of judicial authority. The Court emphasized that it has consistently maintained that the judiciary's power and jurisdiction remain unimpaired despite the proclamation of martial law. It is the Court's role, not the Executive's, to determine whether it can take cognizance of cases involving the validity of executive acts. The reasoning that the validity of acts done pursuant to Proclamation No. 1081 is beyond the courts' power to review is constitutionally erroneous and unworthy of the judicial office. The Court stressed that the independence of the judiciary must be held inviolate at all times as long as the constitution remains in force. On Issue 2: The Supreme Court asserted its inherent, plenary, and imperative power to do substantial justice in every case. When a case is elevated to it for the correction of a procedural error, and it appears that all facts needed for a complete determination of the controversy are before the Court and are undisputed, the Court may, at its option, dispense with the usual procedure of remanding the case to the lower court. This is to avoid unnecessary rigmarole, augment expenses, and delay the administration of justice. In this case, the pleadings portrayed all vital issues, the facts were uncontroverted, and the legal issues were properly joined, with both parties submitting the matter for resolution, thus justifying the Court's decision to resolve the case on the merits.
Main Doctrine
The Supreme Court unequivocally held that the respondent court committed a grave error in dismissing the petition for certiorari and mandamus based on the premise that the validity of acts done pursuant to Proclamation No. 1081 was beyond the court's power to review. The Court asserted that it is the judiciary's prerogative, not the Executive's, to determine whether it may take cognizance of cases involving the validity of executive acts, thereby upholding the independence of the judiciary against unwarranted deference to executive authority, even during martial law.