Case Summary (G.R. No. 182946)
Employment Background
Ruben E. Basco was employed by UCPB as a Bank Operations Manager for seventeen years and was a stockholder with ownership of 804 common shares. In addition to his role at UCPB, he worked as an underwriter for United Coconut Planters Life Association (Coco Life) since December 1992, soliciting insurance policies from bank employees. Basco's employment was terminated on June 19, 1995, based on allegations of grave abuse of authority and breach of trust. Following his dismissal, he filed complaints for illegal dismissal and damages with the National Labor Relations Commission (NLRC).
Legal Dispute
Despite the ongoing legal proceedings, Basco continued to conduct business at UCPB, soliciting insurance from employees. In a memorandum dated November 15, 1995, UCPB instructed to bar Basco from the bank premises due to the pending cases and his prior dismissal. On December 7, 1995, Basco, through counsel, requested reconsideration of his exclusion, but UCPB maintained that the memorandum was necessary for maintaining confidentiality and security.
Incidents of Restriction
On January 31, 1996, while attempting to conduct business with the bank, Basco was approached by security personnel and asked to leave based on the aforementioned memorandum. He sought to retrieve a check and deposit some money while sitting on a sofa in the lobby area. When he attempted to approach bank employee Jose Regino Casil, security intervened, resulting in Basco’s complaint for damages against UCPB and Ongsiapco for humiliation and violation of his rights as a stockholder and depositor.
Legal Proceedings
The RTC ruled in favor of Basco, awarding him damages and ordering the rescission of the memorandum barring him from bank premises, concluding that UCPB acted abusively. The bank’s appeal to the Court of Appeals sought to overturn this decision, questioning the actions taken under the memorandum, the classification of damages, and the legitimacy of a counterclaim for damages due to Basco's previous litigation against them.
Appellate Court Ruling
On March 30, 2000, the Court of Appeals modified the RTC ruling, removing the awards for moral and exemplary damages but granting nominal damages of P25,000 for UCPB’s excessive use of self-help when they barred Basco from accessing the ATM area. The appellate court reasoned that the security personnel should have waited to ensure Basco entered the restricted area before intervening.
Issues Presented
Before the Supreme Court, the petitioners raised issues regarding excessive self-help measures taken by the bank, the award of nominal damages, and the validity of their counterclaim.
Supreme Court's Findings
The Supreme Court affirmed that UCPB had a right to protect its premises under Article 429 of the New Civil Code, which allows a lawful possessor to exclude others to maintain security. However, this right could not be interpreted as an abso
...continue readingCase Syllabus (G.R. No. 182946)
Case Overview
- This case involves a petition for review on certiorari by United Coconut Planters Bank (UCPB) and Luis Ma. Ongsiapco against Ruben E. Basco concerning a decision by the Court of Appeals.
- The initial ruling by the Regional Trial Court (RTC) found UCPB liable for damages and attorney's fees to Basco following his illegal dismissal and subsequent barring from bank premises.
Background of the Case
- Ruben E. Basco had a 17-year employment history with UCPB as the Bank Operations Manager at its Olongapo Branch and was a stockholder with 804 shares.
- Basco also worked as an underwriter for Coco Life, a UCPB subsidiary, and solicited insurance policies from UCPB employees.
- On June 19, 1995, UCPB terminated Basco's employment, citing grave abuse of discretion and breach of trust.
- Basco filed a complaint for illegal dismissal and damages against UCPB with the National Labor Relations Commission (NLRC) while continuing to solicit insurance policies from bank employees.
Termination and Access Restrictions
- Following his termination, Ongsiapco issued a memorandum on November 15, 1995, barring Basco from all bank premises, citing ongoing legal proceedings.
- Security guards were instructed to enforce this directive strictly.
- Basco's requests to allow access for legitimate business purposes were denied by UCPB, which maintained that allowing him access could disrupt operations and violate client confidentiality.
Incident Reports
- On December 21, 1995, Basco entered the bank premises to discuss business with employees despite being barred, leading to confusi