G.R. No. 147072 - Lu vs. Spouses Manipon

A student organization known as the Student Leadership Club was formed by some students of the West Visayas College.
Officers were elected, and Violeta Delmo was chosen as the treasurer.
In her capacity as treasurer, Delmo extended loans from the Club’s funds to some students based on Resolution No. 2 passed by the Executive Board, which authorized disbursement of funds for financial aid and humanitarian purposes.

As President of West Visayas College, petitioner Ledesma argued that the act of extending loans violated school rules and regulations.
He sent a letter to Delmo informing her that she was being dropped from the Club membership and would not be considered for any awards or citations from the school.
Delmo’s subsequent request for reconsideration was denied by petitioner.

Delmo appealed to the Office of the Director of the Bureau of Public Schools, prompting an investigation.
The Director’s investigation revealed:

The Club had adopted its Constitution and By-Laws in a meeting held on October 3, 1965, and had passed Resolution No. 2.
There was an existing belief among the Club’s officers that their constitutional documents were approved by the school superintendent based on assurances from the Club adviser, Mr. Jesse Dagoon.
While negligence was found on the part of Mr. Dagoon for failing to secure proper superintendent approval, Violeta Delmo was deemed to have acted in good faith in disbursing the funds.

As a result, the Director ordered that Delmo, as well as all other Club members or officers involved, not be deprived of any award, citation, or honor they might otherwise be entitled to.

On April 27, 1966, petitioner received the Director’s decision along with other case records; simultaneously, he received a telegram regarding misdirected records where the Director only requested the return of the records.
Petitioner mistakenly interpreted the telegram as also instructing him to return the decision and mailed back both the records and the decision.
The next day, after receiving another telegram ordering him to furnish Delmo with a copy of the decision, petitioner sent a night letter asserting that he had already returned the decision and had not retained a copy.
On May 3, 1966, on the day of graduation, another telegram arrived ordering him not to deprive Delmo of any honors; however, it was too late to include her name as an honor student, and she graduated as a plain student instead of receiving the coveted Latin honor of Magna Cum Laude.
Despite further attempts by the petitioner—writing on May 5, 1966, for reconsideration—and his subsequent reversal on July 12, 1966, the issue remained unresolved prior to the commencement exercises.

On July 30, 1966, Delmo, then a minor, was joined by her parents in filing an action for damages against petitioner Ledesma.
During the pendency of the case, Delmo passed away, whereby her parents filed an Amended and Supplemental Complaint as her sole heirs.
The trial court rendered a judgment against petitioner, attributing a series of misconducts and evidencing his bad faith, negligence, and abuse of power by:

Failing to inform Delmo about the Director’s decision.
Deliberately withholding the information even after receiving clear directives via telegram.
Misleading the parties by sending inappropriate communications.

Damages awarded included moral damages, nominal damages, exemplary damages, and attorney’s fees.
The Court of Appeals affirmed the trial court’s decision, prompting petitioner to elevate the issue on petition.

Whether the respondent Court of Appeals erred in affirming the trial court’s finding that petitioner is liable for damages under Article 27 of the Civil Code of the Philippines.

The central question revolved around the petitioner's liability for failing to execute the Director’s decision and denying Delmo the honor she was rightly entitled to.

Whether the petitioner's deliberate acts—including withholding critical information and disregarding superior directives—constituted bad faith and negligence that justified the award of moral and exemplary damages.

The issue further examined if these actions sufficiently demonstrated a violation of the petitioner’s duty as a public officer.

The extent of liability of a public officer when his negligence leads to the deprivation of rights and honors owed to an individual, especially in the context of educational administration.