Garciano v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Esteria F. Garciano was hired to teach during the 1981-82 school year. Before the school year ended, she applied for an indefinite leave of absence to go abroad. Her application was approved. While she was abroad, the school principal, Emerito Labajo, sent her a letter informing her of the decision to terminate her services due to the absence of a written contract and the difficulty of finding a substitute. Upon her return, she received this termination letter. Subsequently, the school's Board of Directors, except for Fr. Joseph Wiertz, signed a letter notifying her of her reinstatement, effective July 5, 1982, and declaring any prior termination notice null and void. Shortly thereafter, several members of the Board of Directors resigned, citing the faculty's negative reaction to the reinstatement decision. Procedural History: Petitioner filed a complaint for damages against school officials and faculty for discrimination and unjust dismissal. The Regional Trial Court ruled in her favor, awarding moral damages, exemplary damages, lost earnings, and litigation expenses. The private respondents appealed to the Court of Appeals, which reversed the trial court's decision, absolving the respondents and dismissing the complaint. The Court of Appeals denied petitioner's motion for reconsideration. The Petition: Petitioner seeks review of the Court of Appeals' decision, arguing that the appellate court erred in absolving the private respondents by faulting her for failing to report back to work.
Issue(s)
Whether the private respondents are liable for damages for the alleged unjust and illegal dismissal of the petitioner. Whether the petitioner's failure to report back to work, despite a reinstatement order, absolves the respondents of liability; and whether the petitioner is entitled to moral and exemplary damages.
Ruling
The petition is dismissed for lack of merit, and the decision of the Court of Appeals is affirmed. The private respondents are absolved from any liability to the petitioner.
Ratio Decidendi
On the issue of liability for damages and unjust dismissal: The Supreme Court affirmed the Court of Appeals' finding that the private respondents should not be held liable. The Court emphasized that the Board of Directors alone possessed the authority to hire and fire teachers. The letter of termination sent by some respondents was admitted to have no legal effect as they lacked the authority to dismiss the petitioner. Furthermore, the Board of Directors subsequently issued a notice of reinstatement, directing the petitioner to report for work. The Court found that the petitioner was not prevented from reporting for work, and her subsequent failure to do so meant that any loss incurred was self-inflicted, invoking the principle of volenti non fit injuria. On the petitioner's failure to report back to work and the claim for moral and exemplary damages: The Court agreed with the Court of Appeals that the petitioner's discontinuance from teaching was her own choice. While the respondents may have desired her termination, they did not physically prevent her from resuming her post as ordered by the Board. The disagreement of the school principal and Fr. Wiertz with the Board's decision, and the alleged threat of faculty resignation, did not constitute grounds for liability. These were viewed as expressions of dissent or free speech, not acts contrary to law, morals, good customs, or public policy. Since the Board's decision to retain her prevailed and she was ordered to report for work but did not comply, her claim for damages, including lost earnings, was deemed self-inflicted. The Court found no basis for awarding moral damages under Article 21 of the Civil Code, as the petitioner was not without fault. Her voluntary departure on an indefinite leave, failure to sign a written contract, and subsequent disregard of the Board's order to report for duty were considered contributing factors. The trial court's award of exemplary damages was also deemed unjustified, as Article 2234 of the Civil Code requires entitlement to moral, temperate, or compensatory damages as a prerequisite for exemplary damages, which the petitioner was not found to be entitled to.
Main Doctrine
A party seeking damages for alleged unjust dismissal must prove that the dismissal was unlawful and that the respondents committed acts that caused damage. If the dismissal was not legally effected and the employee voluntarily desisted from reporting for work despite an order to do so, no damages are recoverable.