G.R. No. L-44484 - Rama vs. Court of Appeals

During the incumbency of Rene Espina as provincial governor of Cebu, Osmundo G. Rama (vice-governor) and Pablo P. Garcia, Reynaldo M. Mendiola, and Valeriano S. Carillo (members of the Sangguniang Panlalawigan) approved Resolution No. 990.
The resolution appropriated funds "for the maintenance and repair of provincial roads and bridges, for the operation and maintenance of the office of the provincial engineer and for other purposes."
A declared policy was set to:

Mechanize the maintenance and repair of all roads and bridges—including those receiving national aid ("JJ").
Economize expenditure from the "JJ" Road and Bridge Fund.
Implement a more comprehensive, systematic, efficient, progressive, and orderly operation and maintenance of the Office of the Provincial Engineer.

To operationalize the declared policy, the provincial board resolved to abolish around thirty positions (including various roles such as highway maintenance workers, foremen, watchmen, drivers, mechanics, and support staff).
Approximately 200 employees were eased out from their positions, effectively ending the traditional caminero (pick-shovel-wheelbarrow) system.
In support of mechanization, the provincial government purchased heavy equipment worth P4,000,000.00.
Contrary to the declared policy to economize, later actions showed:

Their objectives included the annulment of Resolution No. 990, reinstatement of positions, and recovery of damages.
In Civil Case No. R-10704, the Court of First Instance of Cebu declared Resolution No. 990 null and void, ordered the re-creation of abolished positions and reinstatement of 56 petitioners led by Jose Abala, and directed payment of back salaries (damages were not awarded due to lack of legal and factual basis, and attorney’s fees were governed by a contractual agreement).

All parties appealed the lower court’s decision to the Court of Appeals.
The appellate court, particularly through its First Division, modified the decision and ordered that respondent officials pay P1,000.00 moral damages each (in their individual and personal capacity) for a quasi-delict.
Subsequent petitions for review were filed:

Osmundo G. Rama interposed an appeal (G.R. No. L-44484).
Espina, Garcia, Mendiola, and Carillo filed their petition for review (G.R. No. L-44591).
The Province of Cebu and its Sangguniang Panlalawigan also pursued a petition for review (G.R. No. L-44894).

Cases L-44842, L-44591, and L-44484 were consolidated, and separate motions to dismiss were raised by employees (Frondoso and Luna) in related cases (L-44842 and L-44894) arguing that they were barred by the rule of stare decisis due to the dismissal of a similar petition (L-44572).

The Court examined the contention regarding the timeliness of appeals and the jurisdiction over the petition of Frondoso and Luna.
It held that the liberal interpretation of timeliness principles and the affordance of ample opportunity to litigate rendered the jurisdictional contention unmeritorious.
Consequently, the petition filed as L-44894 was dismissed in light of the dismissal of L-44572 and its identical issues.

The factual findings revealed that the dismissed employees were eased out due to their party affiliation (they belonged to the Liberal Party, opposing the political interests of the petitioners).
The petitioners’ actions were characterized as being motivated by a desire to oust political opponents in favor of their own proteges.
Despite subsequent actions by petitioners (such as reinstating many employees through Resolution No. 392), these did not negate the damage suffered during the period of enforced unemployment.

Whether the abolition of about thirty positions through Resolution No. 990 was legal and justified.
Whether the subsequent contradictory hiring and benefits provided undermined the declared policy of economization.

Whether the petitioners (Espina, Rama, Garcia, Mendiola, and Carillo) can be held personally liable for damages arising from the cancellation of employment.
Whether the act of dismissing employees solely due to their political affiliation constitutes a wrongful act (quasi-delict).

Whether the appeals (especially in cases L-44842 and L-44894) were properly submitted and fall within the principles of providing ample opportunity for proper adjudication.
Whether the rule of stare decisis applies in dismissing some petitions because of identical issues previously dismissed.

Whether the awarding of P1,000.00 moral damages to each petitioner is appropriate under the circumstances.
The extent to which the dismissed employees suffered special and peculiar injuries that warrant additional compensation beyond back salaries.