G.R. No. 185559 - Tan vs. Valeriano

Case Summary (G.R. No. 185559)

Background of Administrative Complaints

During the conference, Valeriano delivered the welcome address and allegedly criticized some local officials, including petitioners. Petitioners, together with Gilana and Gonzales, believed the conference was politically charged and that Valeriano engaged in electioneering and partisan politics, which are prohibited to civil service employees. Consequently, on January 5, 2001, they filed an administrative complaint before the Civil Service Commission (CSC) against Valeriano, accusing him of violating rules against political activity by civil servants.

Procedural History of Complaints

The COA, Valeriano’s employer, was informed but took no action due to the case pending before the CSC. The CSC initially dismissed the complaint on January 30, 2001, due to a procedural defect—the complaint was not sworn—but allowed for its refiling. Petitioners later refiled the complaint on March 23, 2001, but eventually withdrew it on June 15, 2001. Additionally, petitioners and Gilana filed a separate administrative complaint before the Office of the Ombudsman for alleged violations of Republic Act No. 6713 and the Revised Administrative Code, which was dismissed for lack of evidence on June 21, 2001.

Regional Trial Court’s (RTC) Findings

Valeriano sued petitioners for damages based on malicious prosecution. The RTC ruled in favor of Valeriano, finding that the complaints were filed with malice, vindictiveness, and bad faith. The court noted that Valeriano only delivered the welcome address and did not engage in the partisan activities alleged. It held that the multiple filings without substantive basis were indicative of ill will. The RTC awarded Valeriano moral damages of P300,000, exemplary damages of P200,000, and attorney’s fees of P30,000.

Court of Appeals’ (CA) Decision

The CA partially reversed the RTC decision by absolving Gonzales and Gilana, as their actions were not proven to be malicious or in bad faith. However, the CA affirmed the liability of petitioners Tan and Luzuriaga, reasoning that their refiling of the complaint with the CSC, despite a pending Ombudsman case, showed bad faith and the intent to injure Valeriano. The CA emphasized that petitioners failed to disclose the pending Ombudsman case to their counsel, reinforcing the finding of malice.

Issue for Resolution

The central issue is whether petitioners acted with malice or bad faith in filing the administrative complaints against Valeriano, thereby justifying the award of damages for malicious prosecution.

Supreme Court’s Analysis on Scope of Review

The Court underscored that under Rule 45, a petition for review on certiorari is limited to questions of law and not factual disputes. Exceptions allowing factual review require extraordinary circumstances, such as findings based entirely on speculation or grave abuse of discretion, none of which apply here.

Legal Principles on Abuse of Rights and Malicious Prosecution

Article 19 of the Civil Code establishes the principle of abuse of rights, obliging all to act with justice, honesty, and good faith. The elements of abuse of rights are:

Existence of a legal right or duty.
Exercise of such right in bad faith.
Intent to prejudice or injure another.

Malicious prosecution requires proof of legal malice, i.e., that the suit was initiated with a sinister design to vex, humiliate, or injure, and that it was baseless. Merely filing a complaint does not constitute malicious prosecution if done in good faith.

Analysis on Petitioners’ Intent and Basis for Filing Complaints

Valeriano’s role in the consultative conference—particularly as president of the religious organization sponsoring an event critical of local officials close to election time—raised concerns under the Constitution and the Revised Administrative Code which prohibit civil service employees from engaging in partisan political activities. Section 2, Article XI of the 1987 Constitution and Section 55 of the Revised Administrative Code explicitly prohibit such conduct.

Given these prohibitions, petitioners’ filing of complaints against Valeriano was rooted in a reasonable belief that he might have violated the law. The dismissal of the initial CSC complaint was due to a technicality (lack of sworn complaint), and the CSC’s allowance for refiling negates any presumption of bad faith in the renewed complaint.

Court’s Rejection of the Allegation of Malice

The Supreme Court found no clear proof that petitioners acted with malice. Good faith is presumed, and the burden of proving bad faith lies on the party alleging it. Valeriano failed to establish that the complaints were motivated by any sinister purpose to vex or harass him. The complaint was supported by a reasonable belief in Valeriano’s violation of the law rather than personal animosity or malicious intent.

The Court also clarified that filing of complaints for legitimate purposes, even if they ultimately fail, does not ground liability in malicious prosecution. The mere re

Case Syllabus (G.R. No. 185559)

Case Background and Parties Involved

The case arises from a damages suit for malicious prosecution filed by respondent Romeo H. Valeriano against petitioners Jose G. Tan, Orencio C. Luzuriaga, Toby Gonzales, and Antonio G. Gilana.
On January 4, 2001, the Holy Name Society of Bulan, Sorsogon, held a multi-sectoral consultative conference, where Valeriano, president of the said religious organization and employed as a resident auditor by the Commission on Audit (COA), delivered the welcome address.
Valeriano allegedly criticized local officials, including petitioners who were Municipal Councilors, as well as Vice-Mayor Gonzales and Gilana.
The next day, petitioners, along with Gonzales and Gilana, filed an administrative complaint against Valeriano with the Civil Service Commission (CSC) for alleged electioneering and partisan political activity.
Petitioners believed the conference intended to select candidates endorsed by the Holy Name Society and construed Valeriano’s remarks as setting a political tone.
The COA was informed of the complaint but took no action due to the case pending at the CSC.

Course of Administrative Complaints

The CSC dismissed the initial complaint on January 30, 2001, due to procedural defects—specifically, the complaint-affidavit was not sworn—but allowed re-filing.
Petitioners re-filed the complaint on March 23, 2001, but later withdrew it on June 15, 2001.
Subsequently, on March 22, 2001, petitioners and Gilana filed another administrative complaint before the Office of the Ombudsman for violations of RA No. 6713 and Section 55 of the Revised Administrative Code of 1987.
The Ombudsman dismissed this subsequent complaint on June 21, 2001, citing lack of evidence.

Regional Trial Court (RTC) Decision

Valeriano filed a damages suit for malicious prosecution before the RTC, asserting the administrative complaints were filed with malice and bad faith.
The RTC found that the multiple complaint filings were motivated by malice, vindictiveness, and a desire for revenge, considering that Valeriano was unfairly singled out despite limited participation in the conference.
The trial court held that the complaints filed before the CSC, COA, and Ombudsman were baseless and reflected ill will.
Consequently, the RTC awarded Valeriano moral damages (P300,000), exemplary damages (P200,000), and attorney’s fees and litigation expenses (P30,000).

Court of Appeals (CA) Ruling

The CA reversed the RTC’s ruling in favor of Gonzales and Gilana, finding no malice or bad faith on their part in filing the initial complaints.
However, the CA affirmed that petitioners Jose G. Tan and Orencio C. Luzuriaga were liable for damages due to bad faith manifested by re-filing the complaint with the CSC despite the Ombudsman case’s pendency.
The CA also pointed to petitioners’ failure to inform their counsel of the pending Ombudsman complaint as indicative of intent to prejudice Valeriano.

Legal Issue

The central legal issue is whether the petitioners acted with malice or bad faith when filing the administrative complaints against Valeriano, thereby warranting