Case Digest (G.R. No. 96126)
Facts:
Esteria F. Garciano v. The Hon. Court of Appeals, G.R. No. 96126, August 10, 1992, First Division, Grino‑Aquino, J., writing for the Court.Petitioner Esteria F. Garciano was hired as a teacher for the 1981–82 school year at the Immaculate Concepcion Institute (ICI), Camotes Island. On January 13, 1982 she applied for an indefinite leave of absence to accompany her daughter abroad; the application was recommended by Principal Emerito O. Labajo and approved by the President of the school’s Board of Directors (Exhs. B, B‑1).
On June 1, 1982 Principal Labajo sent a letter to petitioner (through her husband) informing her of a decision, attributed to Fr. Joseph Wiertz (the school’s founder) and concurred in by the PTA president and some faculty members, to terminate her services. The stated grounds were her refusal to sign a written employment contract and the difficulty of securing a substitute without such a contract (Exhs. C and 1). Upon returning from Austria later in June 1982 she received that termination letter and inquired about it.
On July 7, 1982 a majority of the Board of Directors (all except Fr. Wiertz) signed a letter reinstating petitioner effective July 5, 1982 and declaring any prior termination letters null and void (Exhs. D and 2). Two days later, on July 9, 1982, four board members (the president, vice‑president, secretary and three members — actually a plurality of the Board’s nine members) resigned, stating that the faculty had reacted strongly to the Board’s reinstatement decision (Exh. E).
Petitioner filed a complaint for damages in the Regional Trial Court (RTC), Cebu, Branch XI, on September 3, 1982, against Fr. Wiertz, Principal Labajo and certain faculty members for discrimination and unlawful dismissal. After trial the RTC rendered judgment on August 30, 1985 in petitioner’s favor, awarding P200,000 moral damages, P50,000 exemplary damages, P32,400 lost earnings for nine years, and P10,000 litigation expenses and attorney’s fees.
The defendants appealed to the Court of Appeals (CA‑G.R. CV No. 10692). On August 30, 1990 the Court of Appeals reversed the RTC and dismissed the complaint, absolving the defendants of liability and ordering costs against the plaintiff‑appellee; its denial of petitioner’s motion for reconsideration followed on O...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in absolving the private respondents from liability by attributing petitioner’s loss to her failure to report for work?
- Were the private respondents liable for unlawful dismissal or entitled petitioner to recover moral, exemplary damages...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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