G.R. No. L-17620 - Far Eastern University vs. Court of Industrial Relations

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G.R. No. L-17620: Far Eastern University vs. Court of Industrial Relations

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Title Source: Supreme Court: Obra vs. Court of Appeals

Case: G.R. No. 120852

Decision Date: Oct 28, 1999

Bretts’ truck seized without due process; Supreme Court upheld damages for constitutional rights violation under Article 32, affirming lower courts.

Case Digest (G.R. No. L-17620)
Expanded Legal Reasoning Model

Facts:

Background and Initiation of the Complaint

Petitioner Benjamin D. Obra was serving as the Regional Director of the Bureau of Mines and Geo-Sciences (BMGS) in Baguio City.
On June 26, 1985, Jeannette M. Grybos, representing the Gillies heirs of Palasa-an, Mankayan, Benguet, sent a letter alleging that private respondents, spouses James Brett and June Prill Brett, were engaged in illegal mining operations in an area belonging to the Gillies family.
The complaint emphasized:

The commencement of unauthorized mining activities since 1981.
The extraction of ore without the necessary permits.
A request for investigation, inspection, and confiscation of the mining equipment used by the respondents.

Actions Taken by Petitioner Obra

On receiving the complaint, Obra sent a letter on the same day to Brig. Gen. Tomas Dumpit, then Commanding General of the Regional Unified Command I (RUC-1) of the Philippine Constabulary, requesting assistance in apprehending a blue and yellow Isuzu truck allegedly used to transport illegally mined ore.
Obra’s communication with Dumpit specifically mentioned:

The need to check and apprehend the vehicle passing through the military outpost at Camp Dangwa.
The requirement for the BMGS to be informed once the truck was apprehended so that proper legal action could follow.

Preparatory Notices and the Scheduled Investigation

On June 27, 1985, Obra issued letters to both private respondents and Ms. Grybos notifying them that the BMGS was to conduct an ocular inspection and field investigation at Palasa-an from July 2 to 5, 1985.
Additional steps included:

Requesting the presence of the respondents and their witnesses to ascertain factual and technical details.
Issuing a similar letter to Col. Bernardo Estepa, Provincial Commander of Benguet, requesting a temporary halt to any mining operations in the area until the investigation concluded.

Execution of the Seizure

On July 1, 1985, elements of RUC-1, under Major Guillermo Densen and led by Sgt. Josefino A. Morales, seized an Isuzu AELFa truck (ABX-587) owned by the private respondents as it entered the Mamakara mining area.
The truck was impounded by the military and its use limited strictly to mercy missions, such as transporting sick soldiers and essential supplies for the military personnel.

Filing of the Complaint by Private Respondents

Private respondents initiated a complaint for injunction and damages, seeking:

A temporary restraining order citing the absence of a prior investigation and probable cause.
Damages including actual and compensatory, moral, exemplary damages, and attorney’s fees.

The Regional Trial Court, Branch 8, of Baguio and Benguet eventually ruled in favor of the respondents, awarding P100,000 for the violation of constitutional rights and P10,000 for attorney’s fees.
The Court of Appeals subsequently affirmed the trial court’s decision.

Contentions Raised on Appeal

Petitioners argued that:

Their conduct in ordering the seizure was in the performance of their official duties and executed in good faith.
They were entitled to an award of damages under the provisions of P.D. No. 1281, as amended, which empowered the BMGS Director to order seizure and to deputize law enforcement personnel.

They relied on the relevant provisions of the decree and a quoted section of the 1973 Constitution that authorized warrantless actions under certain circumstances.

Legal and Evidentiary Context

The petitioners’ defense rested on the statutory powers granted by P.D. No. 1281, particularly its provisions allowing seizure and deputization without a prior warrant.
However, evidence showed that:

The seizure was executed without preceding investigation or determination of probable cause.
The certification allegedly supporting the seizure (that no permit had been issued) was not presented in evidence.
Subsequent findings by the BMGS contradicted the basis for the seizure, establishing that respondent June Prill Brett had a valid and subsisting mining claim.

Issues:

Investigation and Probable Cause

Whether Petitioner Obra conducted a proper investigation and obtained a finding of probable cause before ordering the seizure and impoundment of the respondents’ truck.
Whether the reliance on a supposed certification from the BMGS was sufficient and supported by evidence.

Violation of Constitutional Rights

Whether the seizure and ensuing detention of the truck—without a prior investigation—violated the private respondents’ constitutional rights to due process and to security against unreasonable searches and seizures.
Whether the actions taken by petitioners, in light of the available evidence, are constitutionally justified under the provisions of the 1973 Constitution.

Scope of Statutory Powers and Ministerial Duty Defense

Whether the statutory powers granted under P.D. No. 1281 authorize seizure without fulfilling prerequisite conditions such as a prior determination of probable cause.
Whether petitioners can escape liability for damages by invoking the defense that they were merely performing ministerial or good faith duties.

Liability for Constitutional Violations

Whether, under Art. 32 of the Civil Code and the precedent set in Aberca v. Ver, petitioners should be held jointly responsible for the violation of the private respondents’ rights.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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END