Rama v. Court of Appeals
REITERATIONFacts
The Antecedents: During the incumbency of Rene Espina as provincial governor of Cebu, Osmundo G. Rama as vice-governor, and Pablo P. Garcia, Reynaldo M. Mendiola, and Valeriano S. Carillo as members of the Sangguniang Panlalawigan, they adopted Resolution No. 990. This resolution appropriated funds for the maintenance and repair of provincial roads and bridges and for the operation of the provincial engineer's office, declaring a policy to mechanize road and bridge maintenance to economize expenditures. To implement this, around thirty positions were abolished, resulting in the dismissal of approximately 200 employees. The provincial government also purchased heavy equipment worth P4,000,000.00. However, contrary to the policy of economizing, the provincial administration subsequently hired around one thousand new employees, renovated the provincial engineer's office, and provided the engineer with a Mercedes-Benz car. Procedural History: Aggrieved employees filed separate petitions for mandamus, damages, and attorney's fees, seeking the annulment of Resolution No. 990, their reinstatement, and recovery of damages. The Court of First Instance of Cebu declared Resolution No. 990 null and void, ordered the re-creation of abolished positions, provision of funds, reinstatement of 56 petitioners headed by Jose Abala, and payment of back salaries. No damages were awarded. All parties appealed to the Court of Appeals. The Court of Appeals affirmed the lower court's decision with modifications, ordering the respondents to pay jointly and severally in their individual and personal capacity P1,000.00 moral damages to each petitioner, considering the case as a quasi-delict. The Petition: Osmundo G. Rama appealed to the Supreme Court (G.R. No. L-44484). Espina, Garcia, Mendiola, and Carillo filed their own petition for review (G.R. No. L-44591). The Province of Cebu and its Sangguniang Panlalawigan also filed a petition for review (G.R. No. L-44572), questioning the reinstatement with back salaries, which was dismissed by the Supreme Court for lack of merit. Separately, dismissed employees Froilan Frondoso and Jeremias Luna, who had also filed a petition for mandamus, elevated their case to the Court of Appeals. The appellate court, following its previous ruling, held the wrong committed as a quasi-delict and ordered reinstatement with back salaries and payment of moral damages and attorney's fees by the respondent public officials. Frondoso and Luna appealed to the Supreme Court (G.R. No. L-44842), as did the Province of Cebu and its Sangguniang Panlalawigan (G.R. No. L-44894). The Supreme Court consolidated G.R. Nos. L-44484, L-44842, L-44591, and L-44894.
Issue(s)
Whether the Province of Cebu and its Sangguniang Panlalawigan's petition (G.R. No. L-44894) should be dismissed based on the prior dismissal of G.R. No. L-44572. Whether the petitioners (Espina, Rama, Garcia, Mendiola, and Carillo) are personally liable for damages for adopting Resolution No. 990 and dismissing provincial employees. Whether the dismissed employees are entitled to damages and back salaries.
Ruling
In G.R. No. L-44894, the petition for review on certiorari is dismissed for lack of merit. In G.R. Nos. L-44484, L-44591, and L-44842, the decisions of the Court of Appeals are affirmed, holding the petitioners personally liable for damages and ordering payment of back salaries and moral damages.
Ratio Decidendi
On the dismissal of G.R. No. L-44894: The Court found the motion to dismiss meritorious, agreeing with Frondoso and Luna that the issues raised in G.R. No. L-44894 were identical to those in G.R. No. L-44572, which had already been dismissed by the Supreme Court. The Court noted that the prayer in the petition for L-44894 was a verbatim reiteration of that in L-44572. The argument that jurisdiction was not raised in L-44572 was insufficient to save L-44894 from dismissal. The Court reiterated its trend to afford parties ample opportunity to present their cases, thus upholding the Court of Appeals' assumption of jurisdiction over the appeal of Frondoso and Luna, binding the Supreme Court to the dismissal of L-44572 and consequently L-44894. On the personal liability of petitioners: The Court affirmed the principle that a public officer is not immune from personal liability for illegal acts done in bad faith. The petitioners were held personally liable for damages due to their precipitate dismissal of provincial employees through Resolution No. 990. The Court of Appeals found that the employees were "eased out because of their party affiliation," indicating malicious intent to remove followers of a rival political party to accommodate their own proteges. This act was deemed to reflect malicious intent and was not merely the discharge of a public duty but an act to injure individuals. The Court cited jurisprudence holding public officers liable for torts or wrongful acts done in excess or beyond the scope of their duty, and for failure to observe honesty and good faith. On the entitlement to damages and back salaries: The dismissed employees were found entitled to damages because they suffered a special and peculiar injury from the wrongful act of being "plucked out of their positions," leading to uncertainties of unemployment. The Court considered that these employees, holding positions like foremen, watchmen, and drivers, belonged to a low-salaried group who would incur considerable economic hardships when deprived of wages. The P1,000.00 damages granted by the Court of Appeals were deemed judicious and reasonable. The Court also reiterated that dismissed employees are entitled to back salaries as a matter of right. Petitioner Rama's subsequent reinstatement of some employees did not erase his complicity in the adoption of Resolution No. 990, and his benevolent act could not sufficiently compensate for the damage suffered during the period of unemployment.
Main Doctrine
Public officers are personally liable for damages arising from illegal acts done in bad faith, even if done under the guise of official resolutions, especially when such acts are motivated by malicious intent, such as political discrimination.