Pilar v. Sanguniang Bayan of Dasol
REITERATIONFacts
1. The Antecedents: Petitioner, the elected Vice-Mayor of Dasol, Pangasinan, initiated an original action for mandamus seeking to compel the Sanguniang Bayan and the municipal treasurer to pay his salary as mandated by Batas Pambansa Blg. 51 and Circular 9-A. The dispute arose when the Sanguniang Bayan, in Resolution No. 1, increased the salaries of the Mayor and Municipal Treasurer but failed to appropriate a salary for the Vice-Mayor, despite his entitlement to an annual salary of P16,044.00. Petitioner also sought recovery of actual, moral, and exemplary damages, along with attorney's fees. 2. Procedural History: Following the Sanguniang Bayan's initial failure to appropriate his salary, Petitioner made repeated attempts to rectify the situation through letters and official endorsements. The Sanguniang Bayan subsequently enacted resolutions appropriating P500.00 per month in December 1980, later increased to P774.00 per month in December 1981. A subsequent resolution on October 26, 1982, appropriating P15,144.00 for unpaid salaries from January 1, 1981, to December 31, 1982, was vetoed by the respondent Mayor. This led to the filing of the instant petition for mandamus on February 16, 1983. Respondents raised preliminary objections regarding prematurity, exhaustion of administrative remedies, lack of jurisdiction due to factual issues, and mootness. The Supreme Court gave due course to the petition on June 1, 1983. 3. The Petition: The petition, filed as an original action for mandamus, sought to compel the payment of the Petitioner's lawful salary and damages. The core legal issue revolved around whether the appropriation of a vice-mayor's salary was a discretionary or ministerial act. Petitioner argued that mandamus was the appropriate and speedy remedy, bypassing the doctrine of exhaustion of administrative remedies due to the legal nature of the issue and the existence of municipal funds, as certified by the municipal treasurer. Despite the subsequent enactment of an appropriation ordinance and the Petitioner's admission of having been fully paid, the Supreme Court found the Mayor liable for damages and attorney's fees due to his arbitrary veto and bad faith in denying the Petitioner's claim for three years.
Issue(s)
Whether the petition for mandamus has become moot and academic due to subsequent legislative actions. Whether the respondent Mayor acted in gross and evident bad faith in vetoing the resolution appropriating the petitioner's salary. Whether the petitioner is entitled to actual, moral, and exemplary damages, and attorney's fees.
Ruling
The petition is considered moot and academic regarding the claim for salaries. However, the respondent Mayor is ordered to pay the petitioner from his private and personal funds actual damages and costs of litigation in the amount of P5,000.00; moral damages in the amount of P5,000.00; exemplary or corrective damages in the amount of P5,000.00; and attorney's fees in the amount of P5,000.00. Costs are against the respondent Mayor.
Ratio Decidendi
On Issue 1: The Supreme Court considered the petition moot and academic concerning the claim for salaries because the petitioner admitted that at the time he submitted his memorandum, he had been fully paid his salaries as provided by Batas Pambansa Blg. 51 and implemented by Circular No. 9-A. This subsequent payment resolved the primary issue of salary entitlement, rendering the original claim for payment moot. On Issue 2: The Supreme Court found that respondent Mayor Lodovico Espinosa acted in gross and evident bad faith in vetoing the resolution appropriating the petitioner's salary. The Court noted that while vetoing involves discretion, the Mayor exceeded his authority arbitrarily because sufficient municipal funds existed to cover the petitioner's salary. His refusal, neglect, or omission in complying with directives from provincial and national officials to provide and pay the prescribed salary rate was deemed reckless and oppressive. On Issue 3: The Supreme Court ruled that the petitioner is entitled to damages and attorney's fees. This entitlement stems from the fact that the petitioner was forced to litigate for three years to claim his lawful salary, which was unduly denied. The Mayor's actions, characterized as exceeding authority in an arbitrary manner and being reckless and oppressive, justified the award of exemplary or corrective damages for the public good. Actual damages and costs of litigation were reduced to P5,000.00, and moral damages for mental anguish, anxiety, and humiliation were also awarded at P5,000.00. Attorney's fees were fixed at P5,000.00, all to be paid personally by the respondent Mayor from his private funds.
Main Doctrine
While a case may be rendered moot and academic by the subsequent payment of the petitioner's claim, the Supreme Court may still proceed to rule on the issue of damages and attorney's fees if the facts demonstrate that the petitioner was compelled to litigate due to the respondent's unjustified refusal to satisfy a valid claim. Public officials acting in gross and evident bad faith in denying such claims can be held personally liable for actual, moral, and exemplary damages, and attorney's fees.