Case Digest (G.R. No. 253395) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Globe Mackay Cable and Radio Corp. v. Tobias, decided August 25, 1989, private respondent Restituto M. Tobias was employed by petitioner Globe Mackay Cable and Radio Corporation as purchasing agent and administrative assistant to its engineering operations manager. In November 1972, Tobias uncovered large-scale fictitious purchases and fraudulent transactions and reported them to his superiors, Executive Vice-President Herbert C. Hendry and Eduardo T. Ferraren. The following day, Hendry accused Tobias of being the “number one suspect,” ordered him on a forced one-week leave, barred him from office communication, and confiscated his office keys. Upon his return on November 20, Hendry branded him a “crook and swindler,” compelled him to undergo a lie detector test, and to submit handwriting specimens. Two police laboratory reports (December 6 and December 19, 1972) exonerated Tobias, as did negative lie detector results. Undeterred, petitioners procured a preliminary private in Case Digest (G.R. No. 253395) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment and roles
- Restituto M. Tobias (“Tobias”) was hired by Globe Mackay Cable and Radio Corporation (“Globe Mackay”) as a purchasing agent and administrative assistant to the engineering operations manager.
- Herbert C. Hendry, Executive Vice-President and General Manager, and Eduardo T. Ferraren were Tobias’s superiors.
- Discovery of fraudulent transactions
- In 1972, Globe Mackay uncovered thousands of pesos lost through fictitious purchases and other anomalies.
- On November 10, 1972, Tobias reported the irregularities to Ferraren and Hendry.
- Employer’s investigation and treatment of Tobias
- November 11, 1972: Hendry labeled Tobias the “number one suspect,” ordered him on a forced one-week leave, barred office communication, and confiscated office keys and drawer access.
- November 20, 1972: Upon return, Hendry called Tobias a “crook” and “swindler,” mandated a lie detector test, and demanded handwriting, signature, and initial specimens for police examination.
- Forensic findings and criminal complaints
- December 6, 1972: Manila Police Document Examiner issued a crime lab report exonerating Tobias.
- December 10, 1972: Private investigator retired Col. Fernandez produced an incomplete report accusing Tobias.
- December 12, 1972: Hendry suspended Tobias pending criminal charges.
- December 19, 1972: Second police report again cleared Tobias. Lie detector tests were negative.
- Despite exculpatory findings, petitioners filed six criminal complaints (estafa by falsification of commercial documents and violation of Art. 290, RPC), all dismissed by the City Fiscal and affirmed by the Secretary of Justice.
- Employment termination and labor proceedings
- January 17, 1973: Tobias received notice of termination effective December 13, 1972.
- Tobias filed for illegal dismissal; the Labor Arbiter dismissed; NLRC reversed; Secretary of Labor reinstated Arbiter; appeal to Office of the President; compromise agreement executed.
- Post-termination defamation and civil suit
- Tobias sought employment at RETELCO; Hendry unsolicitedly sent a letter branding Tobias dishonest, resulting in rejection.
- Tobias filed a civil suit for damages. The RTC awarded P80,000 actual, P200,000 moral, P20,000 exemplary damages, P30,000 attorneys’ fees, and costs. The Court of Appeals affirmed. Petitioners’ certiorari petition to the Supreme Court ensued.
Issues:
- Whether petitioners abused their right to dismiss Tobias, rendering them liable for damages under Articles 19, 20, and 21 of the Civil Code.
- Whether petitioners committed torts—defamation, malicious prosecution, and quasi-delicts—by harassing Tobias during investigations, filing baseless criminal complaints, and sending the RETELCO letter.
- Whether the RTC and CA awards of actual, moral, exemplary damages, and attorneys’ fees were proper and not excessive.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)