Case Digest (G.R. No. L-32312) Core Legal Reasoning Model
Facts:
The case involves Aurelio Tiro, who was the City Superintendent of Schools of Cebu City, as the petitioner-appellant, against Honorable Agapito Hontanosas, Judge of the Court of First Instance of Cebu, Branch XI, and respondents-appellees, Zafra Financing Enterprise and Marcelino Zafra. The dispute arose from Civil Case No. 11616 filed before the defunct Court of First Instance of Cebu. Zafra Financing Enterprise had extended loans to public school teachers in Cebu City, who, as a result, executed promissory notes and special powers of attorney in favor of Zafra. These authorized Zafra to collect the teachers’ salary checks directly from the Division Office of the Bureau of Public Schools in Cebu City. However, Superintendent Aurelio Tiro prohibited the collection of salary checks by third parties based on Circular No. 21, series 1969, issued by the Director of Public Schools on December 5, 1969. This circular prohibited the payment of salary checks to anyone other than the emp
Case Digest (G.R. No. L-32312) Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Aurelio Tiro, Superintendent of Schools in Cebu City, was sued in his official capacity by Zafra Financing Enterprise and Marcelino Zafra.
- Zafra Financing Enterprise extended loans to public school teachers in Cebu City. The teachers executed promissory notes and special powers of attorney in favor of Zafra to allow the collection of their salary checks from the Division Office of the Bureau of Public Schools.
- Conflict
- Superintendent Tiro forbade the collection of the salary checks by Zafra, relying on Circular No. 21, series of 1969, issued by the Director of Public Schools.
- Circular No. 21 prohibited payment of salary to persons other than the employee himself/herself, with certain exceptions such as immediate family members or upon authorization from appropriate authorities.
- Proceedings Below
- Zafra sought a declaration that Circular No. 21 was illegal, an order compelling Tiro to recognize the special powers of attorney, and payment of attorney’s fees and damages.
- The trial court ruled in favor of Zafra, except it denied monetary claims against Tiro, acknowledging his good faith in enforcing the Circular.
- Appeal
- Tiro elevated the case through a petition for review to seek reversal of the lower court’s decision.
Issues:
- Whether Circular No. 21, series of 1969, prohibiting payment of salary to persons other than the employee concerned except under specified exceptions, is valid and enforceable.
- Whether the Circular violates the obligation of contracts between Zafra Financing Enterprise and public school teachers.
- Whether Aurelio Tiro, as Superintendent of Schools, acted beyond his authority in refusing to honor the special powers of attorney presented by Zafra.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)