G.R. No. 157070 ; January 14, 2005
JOSEFINA ESTOLAS and RICARDO SALVADOR, petitioners, vs. RAYMUNDO ACENA, respondent.

FACTS

Raymundo Acena was the permanent Administrative Officer of Rizal Technological College (RTC). On December 9, 1985, he was given a promotional appointment as Associate Professor, effective November 1, 1985, and was concurrently designated as Acting Administrative Officer. On January 9, 1986, Acena rejected the Associate Professor appointment, citing his lack of a master’s degree required for permanency. President Lydia Profeta accepted his rejection on January 13, 1986. Subsequently, on April 8, 1986, the new Officer-in-Charge, petitioner Josefina Estolas, issued Memorandum Order No. 30, revoking Acena’s designation as Acting Administrative Officer and replacing him with petitioner Ricardo Salvador.
Acena filed a complaint for injunction and damages with the Regional Trial Court (RTC), asserting that the revocation violated his security of tenure. The trial court, relying on a favorable 1987 opinion from a Civil Service Commission (CSC) Chairperson, issued a writ of preliminary injunction on May 15, 1987, ordering Estolas to cease implementing Memorandum Order No. 30. Despite this court order, petitioner Estolas subsequently secured the renewal of Acena’s temporary appointment as Associate Professor for several years and endorsed his earlier-rejected appointment papers to the CSC.

ISSUE

Whether petitioners Josefina Estolas and Ricardo Salvador acted in bad faith, making them jointly and severally liable for moral and exemplary damages to respondent Raymundo Acena.

RULING

Yes. The Supreme Court affirmed the awards of moral and exemplary damages. The legal logic rests on the principle that a public official’s discretionary powers must be exercised in good faith. While the Court in a related case (Acena v. CSC) ultimately ruled that the CSC correctly found Estolas’s revocation order to be valid, her subsequent actions, undertaken after the trial court had issued a preliminary injunction, demonstrated bad faith. The injunction order was premised on a finding that Acena’s revocation was illegal at that juncture. Estolas’s defiance of this judicial order by renewing Acena’s temporary appointments in a position he had rejected constituted willful disregard of the court’s authority and an attempt to undermine Acena’s legal position.
This willful injury, committed in a manner contrary to morals and good customs, establishes a cause of action for damages under Article 19 of the Civil Code. The factual findings of the trial court, affirmed by the Court of Appeals, that these acts caused Acena besmirched reputation, mental anguish, and social humiliation, sufficiently justify the award of moral damages. The existence of bad faith further warrants exemplary damages to serve as a deterrent against the oppressive exercise of official authority. Thus, petitioners’ liability for damages is sustained.