G.R. No. 80160 June 26, 1989
GOVERNOR FELICISIMO T. SAN LUIS, THE SANGGUNIANG PANLALAWIGAN, PROVINCIAL ENGINEER JUANITO C. RODIL AND PROVINCIAL TREASURER AMADEO C. ROMEY, ALL OF LAGUNA, petitioners, vs. COURT OF APPEALS AND MARIANO L. BERROYA, JR., respondents.

FACTS

Mariano L. Berroya, Jr., the Quarry Superintendent of Laguna since 1959, exposed graft and corrupt practices within the provincial government in April-May 1973. Subsequently, Governor Felicisimo T. San Luis issued Office Order No. 72 on July 20, 1973, transferring Berroya to the Office of the Provincial Engineer. Berroya challenged this transfer before the Civil Service Commission (CSC), which ruled it illegal and ordered his reinstatement to his original position on October 25, 1973. Instead of complying, Governor San Luis suspended Berroya for one year on December 12, 1973, on charges of gross discourtesy, inefficiency, and insubordination.
The CSC again ruled the suspension illegal and reiterated its reinstatement order on February 26, 1974. Governor San Luis appealed to the Office of the President (OP). While this appeal was pending, the OP initially reversed the CSC but later, in OP Decision 1834 (1976), set aside its own reversal, declared the suspension improper, and ordered payment of back salaries. Undeterred, Governor San Luis dismissed Berroya on April 27, 1977, for alleged neglect of duty and abandonment of office. The CSC, on January 23, 1979, declared this dismissal unjustified, exonerated Berroya, and directed his reinstatement. Governor San Luis repeatedly sought reconsideration from both the CSC and OP, all of which were denied. Berroya’s formal demand for reinstatement was ignored, prompting him to file a mandamus suit.

ISSUE

The primary issue is whether a writ of mandamus lies to compel the reinstatement of a wrongfully dismissed government employee, and whether the public official responsible for the illegal acts can be held personally liable for damages.

RULING

Yes, mandamus is the proper remedy. The Supreme Court affirmed the Court of Appeals’ decision, holding that Berroya had a clear legal right to reinstatement, and the petitioners, in their official capacities, had a corresponding ministerial duty to comply with the final and executory orders of the CSC and the OP. The Court emphasized that administrative decisions which have become final and executory must be respected and implemented. Governor San Luis’s persistent refusal to reinstate Berroya, despite these conclusive rulings, constituted a blatant disregard of lawful orders and made mandamus appropriate to compel performance of a duty.
Furthermore, the Court sustained the award of moral damages and attorney’s fees against Governor San Luis in his personal capacity. The legal logic is that a public official who acts arbitrarily, oppressively, and beyond the scope of his authority is not immune from personal liability. Governor San Luis’s obstinate defiance of final administrative directives, aimed at vindictively persecuting an employee for exposing anomalies, was a wrongful act that directly caused Berroya mental anguish, serious anxiety, and litigation expenses. Such personal liability is separate from the government’s liability for back salaries. The Court modified the appellate decision, ordering payment of five years’ back salaries in petitioners’ official capacities and, since Berroya had reached retirement age, all retirement benefits due. Governor San Luis was personally ordered to pay P50,000.00 as moral damages and P20,000.00 as attorney’s fees and costs.