G.R. No. L-48076 February 12, 1980
ARANETA UNIVERSITY FOUNDATION, JUAN SALCEDO, JR., TOMAS DAVID, MARTIN CELINO, MARCELO C. AMIANA, THOMAS P.G. NEILL and MEMBERS OF THE BOARD OF TRUSTEES, petitioners, vs. HON. MANUEL A. ARGEL, and FELIX MONTEMAYOR, respondents.

FACTS

Private respondent Felix Montemayor, a professor, was dismissed by petitioner Araneta University Foundation. He initially challenged this dismissal before the Secretary of Labor, but the Supreme Court, in a prior case (Montemayor v. Secretary of Labor), ultimately upheld the Secretary’s finding that the administrative procedure leading to the dismissal clearance did not violate procedural due process. The Court explicitly clarified that its ruling was limited to the administrative process and did not constitute a factual finding on the merits of the immorality charge against Montemayor.
Subsequently, Montemayor filed a civil case for damages against the university and its officials before respondent Judge Manuel A. Argel. He alleged that the administrative investigation was a “kangaroo court” conducted in violation of his constitutional rights, making the defendants liable under Article 32 of the Civil Code. The trial court initially dismissed the case, but Judge Argel, motu proprio, issued an order reopening it to allow the defendants to more fully ventilate their defenses. The petitioners now assail this order via certiorari.

ISSUE

Whether the respondent Judge committed grave abuse of discretion in reopening the civil case for damages, considering the Supreme Court’s prior ruling on the administrative aspect of Montemayor’s dismissal.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion. The legal logic hinges on the distinct scope and parties involved in the two proceedings. The Court meticulously explained that its prior decision in the labor case addressed only the specific issue of whether the Secretary of Labor’s act of granting clearance for dismissal was tainted by a denial of due process. The ruling expressly stated it did not make a factual finding on the truth of the immorality charges nor did it exculpate the private university officials from potential liability.
Consequently, the doctrine of “law of the case” invoked by petitioners was inapplicable. That prior judgment, binding only on the parties to that suit (Montemayor and the Secretary of Labor), did not foreclose a separate civil action for damages against different parties—the university and its trustees. Montemayor’s complaint squarely alleged violations of his constitutional rights during the university’s internal investigation, a claim actionable under Article 32 of the Civil Code. This substantive claim for damages had not been adjudicated. Therefore, the trial judge acted within his sound discretion in reopening the case to receive evidence on these unadjudicated allegations. To deny him this opportunity would be an improper diminution of judicial power. The order was a procedural measure to ensure a full hearing, not a prejudgment of the merits, and thus constituted neither an abuse nor a grave abuse of discretion.