Case Summary (A.M. No. P-1279)
Facts of the Case
A significant number of PCA employees were required to apply for clearances that confirmed they had no pending accountabilities for the purpose of obtaining their gratuity benefits. Llorente's role involved approving or denying these clearances. Subsequent to the reorganization, clearances for Mrs. Perez and Mr. Azucena were approved despite outstanding obligations, which were deducted from their gratuity benefits. Conversely, Mr. Hermenigildo Curio faced delays in obtaining his clearance due to pending accountabilities, which were highlighted by Llorente in December 1981.
Charges and Acquittal
An information was subsequently filed against Llorente for allegedly violating Section 3(c) of the Anti-Graft and Corrupt Practices Act due to his refusal to issue Curio a certificate of clearance, thereby depriving him of his gratuity benefits and employment opportunities. However, the Sandiganbayan acquitted Llorente, citing the absence of evident bad faith, and stating that his actions were within legal bounds.
Sandiganbayan's Civil Liability Ruling
Despite acquitting him of criminal liability, the Sandiganbayan held Llorente civilly liable for damages, stating that he abused the rights attributed to him under Articles 19 and 27 of the Civil Code. It determined that his actions, although not made with fraudulent intent, resulted in Curio sustaining damages. The Sandiganbayan found that Llorente's inconsistent treatment of Curio compared to other employees demonstrated a degree of bias that warranted civil liability.
Legal Basis for Decision
The legal framework applied includes the 1987 Philippine Constitution and the Civil Code provisions relevant to good faith and the performance of public duties. It was concluded that Llorente’s actions, while legally oriented, nevertheless resulted in unjust discrimination against Curio. The decision aligns with Article 19 of the Civil Code, which mandates that the exercise of rights should be performed in good faith and with justice.
Damages Awarded
The Sandiganbayan awarded compensatory damages to Curio amounting to P90,000. This figure was calculated based on the projected lost income resulting from Llorente's refusal to issue the clearance. The determination of damages included estimating Curio's potential earnings over five years while accounting for reasonable expenses, emphasizing the financial
...continue readingCase Syllabus (A.M. No. P-1279)
Case Background
- The case revolves around the petition of Atty. David P. Llorente, questioning the Sandiganbayan's decision that held him civilly liable despite his acquittal.
- Atty. Llorente served as a deputy administrator at the Philippine Coconut Authority (PCA) from 1975 until his resignation on August 31, 1986.
- Following a reorganization in 1981, several PCA employees, including Herminigildo M. Curio, were required to secure clearances to access gratuity benefits.
- The clearances were contingent upon the employees settling any pending accountabilities, a condition that was often overlooked in practice.
Key Facts of the Case
- Employee Clearances: Clearances required signatures from PCA officers, including Atty. Llorente, before approval by the corporate auditor.
- Pending Accountabilities: Employees such as Mrs. Perez, Mr. Azucena, and Mrs. Javier had pending financial obligations that were overlooked in their clearances, allowing them to access gratuity benefits.
- Mr. Curio's Situation: Contrarily, Mr. Curio’s clearance was withheld by Atty. Llorente, who cited his pending accountabilities, which included a disallowed cash advance of P92,000.00.
Legal Proceedings
- An Information for violation of the Anti-Graft and Corrupt Practices A