G.R. No. L-54598 April 15, 1988
JOSE B. LEDESMA, petitioner, vs. HON. COURT OF APPEALS, Spouses PACIFICO DELMO and SANCHA DELMO, respondents.

FACTS

Violeta Delmo, a consistent scholar and treasurer of the Student Leadership Club at West Visayas College, extended loans to fellow students pursuant to a club resolution. The school president, Jose B. Ledesma, dropped her from the club and disqualified her from any academic awards, deeming the loans a violation of school rules. Delmo appealed to the Bureau of Public Schools. The Director, after investigation, found she acted in good faith, misled by the negligent faculty adviser. The Director’s decision, received by Ledesma on April 27, 1966, explicitly ordered that Delmo “be not deprived of any award, citation or honor from the school, if they are otherwise entitled thereto.”
Ledesma, upon receiving a telegram asking for the return of the case records, mistakenly returned the decision as well. Despite subsequent telegrams from the Director on May 3, 1966—the day of graduation—directing him not to deprive Delmo of her honors and to furnish her a copy of the decision, Ledesma refused to comply. He did not inform Delmo or her father of the favorable decision, excluded her honors from the commencement program, and failed to announce them during the exercises, claiming he would be “embarrassed” to do so. Violeta Delmo graduated without honors and later passed away.

ISSUE

Whether petitioner Jose B. Ledesma is liable for damages for his failure to implement the Director’s decision and allow Violeta Delmo to graduate with honors.

RULING

Yes, the Supreme Court affirmed the Court of Appeals’ decision holding Ledesma liable for damages. The legal logic centers on Article 27 of the Civil Code, which states that any person who “refuses or fails, without just cause, to comply with a lawful administrative order” shall be liable for damages if another suffers thereby. The Director’s decision was a lawful administrative order that Ledesma, as a subordinate, was bound to enforce. His defense—that he mistakenly returned the decision and had no copy—was untenable. He had read the decision, knew its contents, and received explicit telegraphic orders to comply on the graduation day itself.
His deliberate inaction, refusal to obey his superior, and failure to exercise even basic discretion or courtesy to inform the Delmo family constituted a refusal without just cause. This refusal was attended by bad faith, as he prioritized avoiding personal embarrassment over fulfilling a lawful directive and upholding the student’s vested right to her honors. Consequently, he exceeded the scope of his authority and acted in his personal capacity, making him liable for moral damages to the heirs of Violeta Delmo for the mental anguish caused. The Court also awarded exemplary damages to serve as a public correction for such arbitrary conduct by a public officer. The decision was modified only to clarify that the moral damages were awarded to the spouses as heirs, not in their separate personal capacities.