G.R. No. 180764 - Villanueva vs. Rosqueta

Respondent Emma M. Rosqueta, formerly Deputy Commissioner of the Revenue Collection and Monitoring Group of the Bureau of Customs, tendered her courtesy resignation on January 23, 2001, shortly after President Gloria Macapagal-Arroyo assumed office.
Five months later, on June 5, 2001, she withdrew her resignation, asserting that she enjoyed security of tenure and that her resignation was involuntary—ordered by her superior.

On July 13, 2001, President Arroyo appointed Gil Valera to the position formerly held by Rosqueta.
Rosqueta challenged this appointment, alleging that her removal amounted to an abuse of authority, and filed a petition for prohibition, quo warranto, and injunction against petitioner Titus B. Villanueva (then Commissioner of Customs), the Secretary of Finance, and Valera.

The Regional Trial Court (RTC) of Manila, in Civil Case 01-101539, initially issued a temporary restraining order (TRO) on August 27, 2001, to prohibit Villanueva and the Finance Secretary from implementing Valera’s appointment.
The RTC soon superseded the TRO with a writ of preliminary injunction.
Petitioner Villanueva, along with Valera and the Finance Secretary, challenged the injunction order before the Court of Appeals (CA) in CA-G.R. SP 66070; the CA in turn issued its own TRO on September 14, 2001, although this TRO later lapsed after 60 days.
Eventually, the petition before the CA was dismissed.

On November 22, 2001, while the preliminary injunction in the quo warranto case remained in force, Villanueva issued Customs Memorandum Order 40-2001, authorizing Valera to exercise the powers and functions of the Deputy Commissioner.
During the Bureau’s centennial celebration in February 2002, the commemorative memorabilia (a special Panorama magazine edition and a commemorative billboard) featured all the customs deputy commissioners except Rosqueta. Notably, in the magazine, where her picture was supposed to have appeared, it was instead indicated that her position was “under litigation.”

On February 28, 2002, Rosqueta filed a separate complaint for damages before the RTC of Quezon City (Civil Case Q-02-46256), alleging that Villanueva:

She sought damages amounting to P1,000,000.00 in moral damages, P500,000.00 in exemplary damages, and P300,000.00 for attorney’s fees and costs.
The RTC dismissed her claim, finding that Villanueva had validly and legally replaced her seven months before the centennial event.
The Court of Appeals reversed the RTC’s decision, holding that Villanueva’s failure to comply with the preliminary injunction order demonstrated an abuse of his rights, thereby entitling Rosqueta to recover moral damages.
The CA’s ruling ordered Villanueva to pay P500,000.00 in moral damages, P200,000.00 in exemplary damages, and P100,000.00 in attorney’s fees and litigation expenses.
After Villanueva’s motion for reconsideration was denied, he filed a petition for review on certiorari under Rule 45. The Supreme Court eventually denied the petition and affirmed, with modifications, the CA decision by reducing the awards to P200,000.00 (moral damages), P50,000.00 (exemplary damages), and P50,000.00 (attorney’s fees and litigation expenses).

Whether the Court of Appeals erred in holding petitioner Villanueva liable for damages to respondent Rosqueta on the ground that his refusal to comply with the preliminary injunction constituted an abuse of right.
Whether ignoring the court’s preliminary injunction order—despite receiving alleged legal advice from the Office of the Solicitor General—amounted to bad faith, thereby justifying the awarding of moral and exemplary damages.
Whether the exclusion of Rosqueta from official recognition (such as the centennial memorabilia) was sufficient to establish the injury and resultant damages claimed by her.