Case Summary (G.R. No. L-44484)
Legislative Action and Resolution No. 990
During the administration of Governor Rene Espina, Vice-Governor Osmundo G. Rama, and other members of the Sangguniang Panlalawigan, a resolution, known as Resolution No. 990, was adopted. This resolution appropriated funds for the maintenance and repair of provincial roads and bridges and aimed to mechanize the maintenance system. The resolution declared the intent to replace the "caminero" system, resulting in the abolition of around thirty positions, which led to approximately 200 employees losing their jobs. The provincial government’s actions suggested a contradiction to their stated policy as a significant number of new employees were later hired, and funds were allocated for unnecessary expenditures, such as a luxury vehicle for the provincial engineer.
Legal Proceedings and Initial Rulings
Affected employees filed petitions for mandamus against the provincial officials seeking annulment of Resolution No. 990, reinstatement, and damages. The Court of First Instance ruled in favor of the petitioners, declaring the resolution null and void, ordering the re-creation of the abolished positions, and directing the payment of back salaries, but denying damages due to a lack of a legal and factual basis. The Court of Appeals affirmed this decision but modified it to include the award of moral damages against the public officials in their personal capacities.
Appeals to the Supreme Court
Osmundo G. Rama appealed the appellate court's decision to the Supreme Court, which consolidated multiple related petitions involving the same parties and issues. The Supreme Court also noted the similar nature of petitions filed by other parties concerning the dismissal of employees and the interpretation of jurisdiction.
Quasi-Delict and Personal Liability of Public Officials
The Supreme Court affirmed prior rulings establishing that public officials are not immune from liability for damages in their personal capacities for illegal acts committed in bad faith. The dismissal of provincial employees was pretextually conducted on grounds related to party affiliation, indicating malicious intent, which underpinned the officials' personal liability. The court emphasized that such actions contravene principles of public office and ethics, warranting personal accountability for the damages inflicted on the dismissed employees.
Damages and Legal Justifications
The Court assessed the moral damages awarded to the dismissed employees, recognizing their specialized and peculiar injuries due to wrongful termination. The dismissal not only caused economic hardships but also significant emotional and social distress
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Case Background
- The case revolves around the actions taken by public officials of Cebu during the incumbency of Governor Rene Espina, Vice-Governor Osmundo G. Rama, and members of the Sangguniang Panlalawigan.
- The officials adopted Resolution No. 990, which aimed to mechanize the maintenance of provincial roads and bridges, resulting in the abolition of about thirty positions.
- This action was taken despite a public policy declared to economize and improve the operations of the provincial engineer's office.
Events Leading to the Case
- Approximately 200 employees were laid off as a consequence of the resolution, transitioning from manual labor (caminero system) to mechanized operations.
- Despite the supposed intention to economize, the provincial government later hired around 1,000 new employees and made significant expenditures, including the purchase of heavy equipment worth P4,000,000.00 and the provision of a luxury vehicle for the provincial engineer.
Legal Actions Initiated by Dismissed Employees
- The dismissed employees filed petitions for mandamus, damages, and attorney’s fees, seeking to annul Resolution No. 990 and reclaim their positions.
- They sued the provincial officials in both their official and personal capacities, citing "unjust, oppressive, ille