Case Summary (G.R. No. 171303)
Factual Background
During the Academic Year (AY) 1987-1988, Diaz requested sick leave from November 23, 1987, to March 1, 1988, and returned on March 2, 1988. Following this, she applied for a one-year sabbatical leave with pay, effective June 1988. Initial recommendations favored her application, but eventually, Encanto and the upper administration recommended denial due to inadequate teaching staff. This led to various administrative maneuvers, including withholding Diaz’s salary until requirements were met.
Initial Complaints and Legal Foundations
On January 3, 1989, Diaz filed a complaint with the Office of the Ombudsman against university officials alleging violation of Republic Act No. 3019 due to her salary being contingent on submitting a Report for Duty Form. The Ombudsman dismissed her complaint citing valid grounds for the denial of her sabbatical application.
Regional Trial Court (RTC) Decision
The RTC ruled in favor of Diaz on April 17, 1996, holding that while sabbatical leave is a privilege, the delay in processing her application was unreasonable. It ordered the respondents to pay Diaz unpaid salaries and damages, except for UP and Abueva, noting that Encanto held no liability as her recommendations were timely.
Court of Appeals’ Ruling
Diaz and the respondents both appealed the RTC decision, leading the Court of Appeals on April 28, 2005, to reverse the RTC's ruling. The Court highlighted that Diaz's sabbatical leave was not a right and found no evidence of bad faith or negligence among the respondents regarding the handling of her application and salary withholdings. The Court ordered UP to pay Diaz a reduced amount as unpaid salaries but denied damages.
Supreme Court Proceedings
Diaz appealed to the Supreme Court, raising several assignments of error primarily concerning the alleged bad faith of the respondents. The Supreme Court evaluated the evidence for indications of bad faith, concluding that the respondents did not act maliciously or with intent to harm Diaz. It determined that the previous findings of no malice from both the Ombudsman and the lower courts were to be upheld.
Legal Principles Discussed
The Court referenced Articles 19 and 20 of the Civil Code regarding good faith and the abuse of rights. The ruling reiterated that bad faith must be proven by the alleging party and is not presumed. Both the RTC and the Court of Appeals had similar factual findings but arrived at different conclusions regarding bad faith, necessitating the Supreme Court’s involvement to reconcile these differences.
Final Rulings on Salary and Damages
Ultimately, the Supreme Co
...continue readingCase Syllabus (G.R. No. 171303)
Case Overview
- The case involves a Petition for Review on Certiorari under Rule 45 of the 1997 Rules of Court, aimed at reversing the April 28, 2005 Decision and January 20, 2006 Resolution of the Court of Appeals.
- The case arose from the Regional Trial Court (RTC) decision which favored the petitioner, Elizabeth L. Diaz, in a dispute regarding her sabbatical leave application and the subsequent withholding of her salaries.
Background Facts
- Elizabeth L. Diaz had been employed at the University of the Philippines (U.P.) since 1963, serving as an associate professor in the College of Mass Communication (CMC) in 1987.
- After applying for sick leave from November 23, 1987, to March 1, 1988, Diaz submitted her sabbatical leave application for one year effective June 1988, citing reasons of rest, renewal, and study.
- Initial recommendations for approval were later altered, leading to the eventual denial of her sabbatical leave, which was attributed to staffing shortages within the CMC.
- Diaz's name was removed from the teaching schedule without her knowledge, and her salaries were withheld due to her failure to complete a Report for Duty Form.
Legal Proceedings
- On January 3, 1989, Diaz filed a complaint w