Ricafort v. Bautista
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the mandatory retirement and subsequent reappointment of Maura V. Bautista as President of the Eulogio "Amang" Rodriguez Institute of Science and Technology (EARIST). Bautista was initially appointed President of EARIST in December 1999 for a four-year term. In May 2003, the Board of Trustees (BoT) approved her reappointment effective December 16, 2003, up to age 65, with the possibility of extension beyond that age. This reappointment was further confirmed for a four-year term ending December 17, 2007. In 2005, Bautista reached the mandatory retirement age of 65 and applied for and received retirement benefits from the Government Service Insurance System (GSIS). Despite receiving these benefits, she continued to occupy the office of President. 2. Procedural History: Upon learning of Bautista's retirement application approval, the EARIST BoT, led by petitioner Nona S. Ricafort, issued an unnumbered resolution in April 2006, declaring Bautista's mandatory retirement effective December 1, 2005, and revoking any prior resolutions regarding her reappointment beyond age 65. Consequently, Dr. Enrique R. Hilario was designated as Officer-in-Charge (OIC) of EARIST. Bautista filed a petition for injunction with the Regional Trial Court (RTC) of Manila, seeking to nullify the BoT's resolution and memorandum, and to prevent Hilario from exercising presidential functions. The RTC initially dismissed the petition but later granted a temporary restraining order, reinstating Bautista and ordering Hilario to cease his OIC duties. The case was raffled to RTC Branch 51 after the presiding judge of Branch 41 inhibited himself. RTC Branch 51 ruled that Hilario's designation was improper as the presidency was not vacant under the relevant rules. While finding the injunction tenable, the RTC deemed it improper given Bautista's term was set to expire in December 2007. However, the RTC awarded Bautista actual damages for unearned salary, exemplary damages, and attorney's fees, holding only petitioner Ricafort personally liable. 3. The Petition: This case comes before the Supreme Court via a Petition for Review on Certiorari under Rule 45 of the 1997 Rules of Civil Procedure, seeking to reverse the Court of Appeals (CA) decision that affirmed the RTC's ruling. The petitioners, including Nona S. Ricafort, argue that the award of exemplary damages and attorney's fees lacks basis, asserting that the BoT acted in good faith when it issued the unnumbered resolution and considered Bautista retired. They contend that the BoT merely interpreted Republic Act No. 8292 regarding the extension of a president's term and that the BoT's action was a collegial decision, making it erroneous to single out Ricafort for personal liability. The Supreme Court, however, found that the issues raised involved mixed questions of fact and law, which are generally not reviewable under Rule 45, and affirmed the lower courts' findings that the BoT's actions were not in good faith and that Bautista's reappointment was valid.
Issue(s)
Whether the award of exemplary damages and attorney's fees in favor of the respondent lacks basis. Whether the Board of Trustees acted in good faith when it issued the unnumbered resolution considering the respondent to have retired from service; and whether petitioner Nona S. Ricafort, as Chairperson of the Board of Trustees, should be held personally liable for exemplary damages and attorney's fees. On the Nature of the Petition and Factual Review.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed with modification, imposing a legal interest of 6% per annum on the awarded amounts from the finality of the decision until full satisfaction.
Ratio Decidendi
On the Propriety of Exemplary Damages and Attorney's Fees: The Court held that the resolution of the propriety of exemplary damages and attorney's fees necessitates a review of factual circumstances, which typically falls outside the scope of a Rule 45 petition limited to questions of law. However, the Court found that the lower courts correctly awarded these damages based on established facts. The requisites for exemplary damages were met: they were imposed by way of example for the public good, claimant's right was established, and the act was accompanied by bad faith or done in a wanton, fraudulent, oppressive, or malevolent manner. The award of attorney's fees was also affirmed due to the unjustified refusal of the petitioner to satisfy the respondent's valid claim. On the Good Faith of the Board of Trustees and Petitioner's Liability: The Court affirmed the findings of the lower courts that the Board of Trustees erred in believing that respondent was automatically and compulsorily terminated upon reaching the age of 65. The BoT's approval of respondent's reappointment until December 17, 2007, was in conformity with RA 8292. The Court also affirmed the lower courts' finding of abuse of power by petitioner when she excluded respondent from a conference, leading to the appointment of an OIC and denying respondent due process. This conduct established bad faith, negating the claim of good faith by the BoT and justifying the personal liability of the petitioner. On the Nature of the Petition and Factual Review: The Court reiterated that a petition for review on certiorari under Rule 45 is limited to questions of law, and it is not the Court's function to analyze or weigh evidence, which are tasks for the trial and appellate courts. While exceptions exist for reviewing factual findings, this case did not fall under any of them. The Court found that the petitioner raised mixed questions of fact and law, particularly regarding her alleged lack of malice or bad faith, which required a re-examination of evidence. Despite this, the Court proceeded to affirm the findings of the lower courts based on the evidence presented and the established facts.
Main Doctrine
The Board of Trustees of a state college cannot unilaterally consider an incumbent President as mandatorily retired and appoint an Officer-in-Charge if the President's reappointment was already approved and her term has not yet expired, especially if the President had already applied for and received retirement benefits but continued to discharge her duties without a formal notice of termination. Such action may constitute an abuse of power and a denial of due process, warranting damages.