Case Summary (G.R. No. 157171)
Governing Laws and Regulations
EARIST is a state college established under Presidential Decree No. 1524, and its governing body is the BoT, as defined by Republic Act No. (RA) 8292, also known as the Higher Education Modernization Act of 1997. The significance of this case revolves around the interpretation of the provisions pertaining to the term and appointment of the president.
Appointment and Retirement of Respondent
Respondent Maura V. Bautista was initially appointed as President of EARIST on December 8, 1999, with a term lasting until December 2003. Prior to the expiration of this term, the BoT reappointed her for a second term effective December 16, 2003. This reappointment was initially set until she turned 65, but it included provisions allowing for an extension beyond that age.
Action by the Board of Trustees
In 2005, upon reaching the mandatory retirement age of 65, Bautista applied for retirement benefits from the Government Service Insurance System (GSIS), which were approved, but she did not resign from her position. Subsequently, the BoT passed an unnumbered resolution on April 19, 2006, declaring her to have mandatorily retired effective December 1, 2005, and appointed Dr. Enrique R. Hilario as Officer-in-Charge (OIC).
Legal Action and RTC Rulings
Upon learning of her designation as the OIC, Bautista filed a Petition for Injunction with an application for a temporary restraining order against the implementation of the BoT’s resolution. Initially, the Regional Trial Court (RTC) dismissed her petition but later granted a temporary restraining order, reinstating her as President until further proceedings could confirm the validity of the board’s resolution.
Final Rulings of the RTC and CA
The RTC eventually ruled in her favor on October 14, 2008, declaring that the designation of Dr. Hilario as OIC was improper since Bautista’s position had not been vacated according to the requirements laid out in RA 8292. The RTC awarded her unearned salary as damages, along with exemplary damages and attorney's fees, placing liability solely on Ricafort as an individual based on her perceived abuse of power.
Court of Appeals Decision
On February 28, 2012, the Court of Appeals (CA) affirmed the RTC's decision, upholding the awards granted to Bautista and finding that Ricafort and the BoT had acted in bad faith. The CA also found the award of attorney's fees just and equitable given the refusal to satisfy Bautista’s valid claims.
Supreme Court Findings and Decision
In reviewing the case, the Supreme Court identified that it h
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Case Overview
- The case involves a Petition for Review under Rule 45 of the 1997 Rules of Civil Procedure.
- Petitioners include Nona S. Ricafort, HORACE R. CRUDA, Atty. Armi-Minda Dayot Corpus, Marcelina E. Bacani, Eduardo G. Ong, Ronnie C. Tungul, and Dr. Enrique R. Hilario.
- Respondent is Maura V. Bautista.
- The decision being reviewed was rendered by the Court of Appeals on February 28, 2012, which affirmed the Regional Trial Court's ruling that declared the Board of Trustees' resolution regarding Bautista's mandatory retirement as illegal.
Background of the Case
- The Eulogio "Amang" Rodriguez Institute of Science and Technology (EARIST) is a state college established by Presidential Decree No. 1524.
- Bautista was appointed as President of EARIST on December 8, 1999, for a term ending in December 2003.
- In May 2003, the Board of Trustees passed Board Resolution No. 12-2003, allowing Bautista's reappointment up to age 65, with the possibility of extension.
- Bautista was reappointed for another four-year term starting December 16, 2003.
Events Leading to the Dispute
- Bautista reached the mandatory retirement age of 65 in 2005, applied for retirement benefits from the Government Service Insurance System (GSIS), and received a substantial retirement package.
- Despite her retirement application, Bautista continued to function as President without formally resigning.
- On April 19, 2006, the new Board of Trustees, led by Ricafort, passed a resolution