Case Digest (G.R. No. 127932)
Facts:
The case involves Virginia M. Andrade as the petitioner and Dominador S. Wingsing as the private respondent, with the Court of Appeals also being a respondent. The events leading to the case began on July 6, 1971, when Andrade was appointed as a permanent teacher in the Division of City Schools, Manila, initially assigned to Araullo High School as an English teacher. On June 14, 1985, just two days before the start of the school year 1985-1986, Andrade inquired about her teaching load from the English Department Head, Virginia E. Fermin, who referred her to Principal Wingsing. A subsequent visit on June 19, 1985, yielded no results as Wingsing referred her back to Fermin. Frustrated, Andrade wrote to Arturo F. Coronel, the Assistant Schools Division Superintendent, on July 17, 1985, requesting a teaching assignment.
On July 30, 1985, Wingsing informed Coronel that Andrade was not given a teaching load due to a drastic drop in enrollment, her status as an excess teacher, an...
Case Digest (G.R. No. 127932)
Facts:
Appointment and Initial Assignment
- Petitioner Virginia M. Andrade was appointed as a permanent teacher in the Division of City Schools, Manila, on July 6, 1971. She was initially assigned as an English teacher at Araullo High School, Manila.
Teaching Load Inquiry
- On June 14, 1985, two days before the opening of classes for the school year 1985-1986, petitioner inquired about her teaching load from the English Department Head, Virginia E. Fermin. She was referred to private respondent Dominador Wingsing, the Principal of Araullo High School. However, on June 19, 1985, Wingsing referred her back to Fermin without resolving her inquiry.
Request for Teaching Assignment
- Irked by the lack of resolution, petitioner wrote to Arturo F. Coronel, Assistant Schools Division Superintendent, on July 17, 1985, requesting a teaching assignment. In response, Wingsing cited three reasons for not assigning her a teaching load: (1) a drastic drop in enrollment, (2) she was declared an excess teacher, and (3) she ranked lowest in her performance rating.
Non-Teaching Position Offer
- On August 22, 1985, Superintendent Coronel informed petitioner, through Wingsing, that she would be designated to a non-teaching position pending her reassignment to another school.
Request for Transfer
- On October 4, 1985, petitioner requested a transfer to Ramon Magsaysay High School, which was approved. She reported to Ramon Magsaysay High School on October 9, 1985, but on the same day, she withdrew her transfer request and indicated her intention to remain at Araullo High School.
Exclusion from Payroll
- Petitioner later discovered that her name had been deleted from the regular monthly payroll and transferred to a special voucher list. Feeling aggrieved, she filed an action for damages with mandatory injunction against Wingsing, Fermin, and Coronel before the Regional Trial Court (RTC), Quezon City.
Trial Court Decision
- On August 31, 1990, the trial court absolved Fermin and Coronel but held Wingsing liable for actual and compensatory damages, attorney's fees, and costs of suit.
Appeal to the Court of Appeals
- Wingsing appealed to the Court of Appeals, which reversed the trial court's decision on September 28, 1995, and dismissed petitioner's complaint. The appellate court denied petitioner's motion for reconsideration on January 23, 1997.
Petition to the Supreme Court
- Petitioner challenged the Court of Appeals' decision, arguing that Wingsing failed to comply with applicable laws, including the Civil Service Commission, the Magna Carta for Public School Teachers, and Republic Act No. 2260.
Issue:
- Whether private respondent Wingsing acted in bad faith in declaring petitioner as an excess teacher and excluding her from the regular monthly payroll.
- Whether the applicable laws (Civil Service Commission, Magna Carta for Public School Teachers, and Republic Act No. 2260) were properly observed by Wingsing.
- Whether petitioner was entitled to damages for the alleged withholding of her teaching load and exclusion from the payroll.
Ruling:
The Supreme Court affirmed the decision of the Court of Appeals, holding that:
- Wingsing did not act in bad faith in declaring petitioner as an excess teacher. The decision was based on valid factors such as enrollment drop, petitioner's low performance rating, and her refusal to accept non-teaching assignments.
- The exclusion of petitioner's name from the regular monthly payroll was due to her failure to submit her Daily Time Record (DTR) on time, in accordance with school policy.
- Petitioner failed to prove that Wingsing acted with malice or ill will, and the presumption of good faith in favor of Wingsing remained unrefuted.
Ratio:
- Good Faith Presumption: Good faith is presumed unless proven otherwise. Petitioner failed to provide sufficient evidence to rebut the presumption of good faith on the part of Wingsing.
- Valid Exercise of Authority: Wingsing's actions were based on legitimate reasons, including the drop in enrollment and petitioner's poor performance rating. The declaration of petitioner as an excess teacher was a valid exercise of administrative discretion.
- School Policy Compliance: The exclusion of petitioner's name from the regular payroll was in line with school policy regarding the timely submission of DTRs. There was no evidence of malicious intent on the part of Wingsing.
- No Abuse of Rights: The elements of abuse of rights under Article 19 of the New Civil Code were not met, as there was no showing of bad faith or intent to cause harm.
Conclusion:
The Supreme Court found no merit in petitioner's claims and upheld the decision of the Court of Appeals, affirming that Wingsing acted in good faith and in accordance with school policies and applicable laws.