Case Digest (G.R. No. 96126)
Facts:
The case involves Esteria F. Garciano as the petitioner and Emerito Labajo, Fr. Joseph Wiertz, and several other members of the faculty and Board of Directors of the Immaculate Concepcion Institute as respondents. The events transpired during the 1981-82 school year when Garciano was employed as a teacher at the Immaculate Concepcion Institute located in the Island of Camotes. On January 13, 1982, Garciano applied for an indefinite leave of absence to accompany her daughter to Austria, where her daughter was employed. This application was recommended for approval by the school principal, Emerito Labajo, and subsequently approved by the President of the Board of Directors.
On June 1, 1982, while Garciano was still abroad, Labajo sent a letter to her husband, informing her of the decision made by Fr. Wiertz and the Board to terminate her employment due to the absence of a written contract and the difficulty in finding a substitute teacher. Upon her return in late June 1982, ...
Case Digest (G.R. No. 96126)
Facts:
- Employment and Leave of Absence: Petitioner Esteria F. Garciano was hired as a teacher at Immaculate Concepcion Institute during the 1981-82 school year. On January 13, 1982, she applied for an indefinite leave of absence to accompany her daughter to Austria. Her leave was recommended by the school principal, Emerito Labajo, and approved by the Board of Directors.
- Termination Letter: On June 1, 1982, Labajo informed Garciano’s husband, Sotero Garciano, that her services were terminated due to her refusal to sign a written contract and the difficulty in finding a temporary substitute. This decision was supported by Fr. Joseph Wiertz, the school’s founder.
- Reinstatement Order: Upon her return in June 1982, Garciano received the termination letter but was later reinstated by the Board of Directors on July 7, 1982, effective July 5, 1982. The Board declared the prior termination null and void.
- Resignations and Faculty Reaction: On July 9, 1982, several Board members resigned due to the faculty’s negative reaction to Garciano’s reinstatement.
- Complaint for Damages: On September 3, 1982, Garciano filed a complaint for damages against Labajo, Fr. Wiertz, and other faculty members, alleging discrimination and illegal dismissal. The trial court ruled in her favor, awarding her various damages.
- Appeal to Court of Appeals: Private respondents appealed, and the Court of Appeals reversed the trial court’s decision, absolving the respondents of liability. Garciano’s motion for reconsideration was denied, prompting her to file this petition for review.
Issue:
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Ruling:
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Ratio:
- Authority to Terminate: The Board of Directors alone had the authority to hire and fire employees. The termination letter sent by the private respondents had no legal effect as it was repudiated by the Board.
- Voluntary Discontinuance: The petitioner’s failure to report back to work was voluntary. The private respondents’ disagreement with her reinstatement and the faculty’s reaction did not amount to physical prevention or unlawful acts.
- Damages Under the Civil Code: Liability for damages under Articles 19, 20, and 21 of the Civil Code arises only from unlawful, willful, or negligent acts. Since the respondents did not commit any such acts, they were not liable.
- Moral and Exemplary Damages: The petitioner was not without fault. She went on an indefinite leave, refused to sign a written contract, and ignored the Board’s reinstatement order. Therefore, she was not entitled to moral or exemplary damages.
- Loss of Earnings: The petitioner’s loss of earnings was self-inflicted, and she could not recover damages for it.