G.R. No. 96126 - Garciano vs. Court of Appeals

Case Digest (G.R. No. 96126)
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Facts:

Appointment and Employment

The petitioner, Esteria F. Garciano, was hired to teach during the 1981-82 school year at the Immaculate Concepcion Institute on the Island of Camotes.
Her appointment was contingent upon conditions customary to her employment as a teacher.

Filing for Indefinite Leave of Absence

On or before the end of the school year, specifically January 13, 1982, the petitioner applied for an indefinite leave of absence.
The leave was requested because her daughter was taking her to Austria, where the daughter was employed.
The application was approved based on recommendations from both the school principal, Emerito O. Labajo, and the President of the school’s Board of Directors.

Letter of Termination

On June 1, 1982, while the petitioner was still abroad, Emerito Labajo sent her a letter of termination addressed through her husband, Sotero Garciano.
The termination was based on two main grounds:

The absence of any written contract of employment due to her refusal to sign one.
The difficulty in securing a temporary substitute teacher without a written contract.

The letter was sent via private respondents, including the principal and other faculty members, hence raising questions on their authority.

Reinstatement Efforts

Upon her return from Austria in late June 1982, the petitioner received the termination letter.
Subsequently, on July 7, 1982, inquiries to the school led to the Board of Directors (with the exception of Fr. Joseph Wiertz) issuing a letter reinstating her.

The letter directed her to report for work, effective July 5, 1982.
It declared any prior termination letters null and void.

Internal Dissent and Board Resignations

On July 9, 1982, the president, vice president, secretary, and three other members of the Board of Directors resigned.
Their resignation was in protest, as they contended that the faculty had reacted negatively ("acidly") to the Board’s decision to reinstate the petitioner.

Filing of the Complaint and Trial Court Proceedings

On September 3, 1982, the petitioner filed a complaint for damages before the Regional Trial Court (Cebu, Branch XI).
The complaint was directed against Fr. Joseph Wiertz, Emerito Labajo, and certain faculty members for discrimination and what was claimed as an unjust and illegal dismissal.
After trial, on August 30, 1985, the lower court rendered a decision awarding:

P200,000 as moral damages.
P50,000 as exemplary damages.
P32,400 as lost earnings for nine years.
P10,000 for litigation expenses and attorney’s fees.

Appeal to the Court of Appeals (CA)

The defendants, now private respondents, appealed the decision (CA-G.R. CV No. 10692).
On August 30, 1990, the Court of Appeals reversed the trial court’s decision.

The CA dismissed the complaint, absolving the respondents from any liability.
It held that the respondents had no authority to effectuate the dismissal.

Petition for Review of the CA Decision

The petitioner filed a motion for reconsideration before the CA, which was denied on October 26, 1990.
Subsequently, a petition for review was lodged with the Supreme Court.
The sole error raised was the CA's finding that the petitioner was at fault for not reporting back to work.

Legal and Factual Findings

The Board of Directors, not the private respondents, possessed the authority to hire and fire the petitioner.
The termination letter sent by the private respondents was deemed unauthorized and thus had no legal effect.
The fact that the petitioner later received a reinstatement letter negated the purported termination.
Evidence suggested that the petitioner voluntarily desisted from her teaching duties by not reporting to work despite the reinstatement order.

Relevant Civil Code Provisions and Principles

The case references Articles 19, 20, and 21 of the Civil Code, which discuss:

The duty to act with justice, honesty, and good faith.
The obligation to indemnify for damages caused by unlawful, willful, or negligent acts.
The responsibility to compensate for loss or injury contrary to morals, good customs, or public policy.

The Court underscored that liability arises only when there is an unlawful act that is not self-inflicted.
The principle of volenti non fit injuria was emphasized, pointing out that the petitioner’s inaction contributed to her own damages.

Issues:

Authority of Termination Actions

Whether private respondents had the authority to terminate the petitioner’s employment.
Whether the termination letter sent by the private respondents had any legal effect given the reinstatement issued by the Board.

Petitioner’s Responsibility and Voluntary Act

Whether the petitioner’s failure to report back to work, despite the Board’s order, constitutes a voluntary resignation or abandonment of duty.
Whether this inaction nullifies any claim for damages arising from the purported termination.

Grounds for Damages

Whether the act of the private respondents, including sending the termination letter, qualifies as wrongful dismissal under Articles 19, 20, and 21 of the Civil Code.
Whether the actions of the private respondents, who were simply exercising free speech or dissent, amount to an illegal act warranting damages.

Fault and Liability for Moral Damages

Whether the petitioner’s own missteps (i.e., taking leave, refusing to sign the employment contract, and ignoring the report order) preclude her from recovering moral, exemplary, or compensatory damages.
Whether the petitioner’s actions were self-inflicted, thereby rendering the private respondents free from liability.

Ruling:

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Ratio:

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Doctrine:

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