G.R. No. L-60409 November 11, 1985
Tiburcio Guita, petitioner, vs. Hon. Court of Appeals, Luz Soriano Haguisan & Cesar Benedicto Haguisan, respondents.

FACTS

Cesar Haguisan was employed as a security guard by Marinduque Mining and Industrial Corporation (MMIC). Following a fatal shooting incident involving another guard, all security personnel underwent psychiatric evaluation. Dr. Rena Nora examined Haguisan and found him psychiatrically unfit for the specific position of security guard due to borderline mental capacity, memory impairment, and poor adjustment. Her report, however, noted he could be gainfully employed in other departments requiring less mental alertness. Based on this report, MMIC terminated Haguisan’s services.
Subsequently, Haguisan requested a service certification from petitioner Tiburcio Guita, the MMIC Administrative Officer, for job-seeking purposes. Guita issued a certification stating Haguisan was employed as a security guard from 1956 until his separation in 1971, “after he was found mentally unfit to work.” Haguisan and his wife then sued Guita and others for damages, alleging the certification contained false and derogatory statements designed to ruin his employment prospects. The trial court dismissed the complaint, finding no malice.

ISSUE

Whether petitioner Tiburcio Guita is liable for moral damages for issuing the certification stating Haguisan was “mentally unfit to work.”

RULING

No, Guita is not liable for moral damages. The Supreme Court reversed the Court of Appeals, which had found Guita liable, and reinstated the trial court’s dismissal of the complaint. The Court held that an award of moral damages requires a wrongful act or omission, or proof of fraud or bad faith, which was not established. The appellate court’s finding of malice was bereft of factual support.
The certification must be read as a whole. While it stated Haguisan was “mentally unfit to work,” it explicitly certified his employment as a security guard and his separation from that specific position. Contextually, the statement on mental unfitness could only refer to unfitness for the job of security guard, consistent with the psychiatric report’s core finding. The trial court, which was in the best position to assess witness credibility, expressly rejected the claim that Guita acted with malice or bad faith. Furthermore, the certification was issued solely upon Haguisan’s own request and was delivered only to him. Consequently, no wrongful act was proven to be the proximate cause of any alleged injury, precluding an award of moral damages.