G.R. No. L-54887 May 22, 1982
GUILLERMA FLORDELIS, et al., as heirs of the late GOTARDO FLORDELIS, petitioners, vs. FERMIN MAR, GRACIANO M. LIGAN and COURT OF APPEALS, respondents.

FACTS

Respondents Fermin Mar and Graciano Ligan were public school teachers. Petitioner Gotardo Flordelis, their school administrator, instigated a perjury case against them in 1975. After their initial conviction, the Court of Appeals acquitted them in October 1977. Despite this acquittal, Flordelis prevented them from entering the school, withheld their salaries from December 1975, and filed administrative charges against them. He claimed they refused new assignments, but the Secretary of Education and Culture found his actions irregular and without authority.
The Secretary’s decision dated January 18, 1978, directed the reinstatement of Mar and Ligan with back salaries. Prior to this, in July 1977, the teachers filed a mandamus action in the Court of First Instance to compel reinstatement and recover damages. The trial court ordered reinstatement with back wages and awarded moral and exemplary damages. The Court of Appeals affirmed but reduced the damages. Flordelis appealed to the Supreme Court but died during pendency; his heirs were substituted.

ISSUE

The primary issue is whether the late school administrator, Gotardo Flordelis, is personally liable for moral and exemplary damages for his unauthorized acts of suspending the teachers and withholding their salaries.

RULING

The Supreme Court affirmed the decision of the Court of Appeals, holding Flordelis personally liable for damages. The legal logic rests on the finding that Flordelis acted with evident bad faith and beyond his official authority. As a mere school administrator, he lacked the statutory power to suspend subordinates or withhold their salaries; such authority was vested only in higher officials like regional directors or the department secretary under the Civil Service Decree. His actions persisted even after the teachers’ acquittal and a direct order from the Secretary of Education for their reinstatement.
This constituted a willful and oppressive disregard of the teachers’ rights, making the act not merely an error in judgment but a personal wrong. Consequently, the award of moral damages was justified under Article 21 of the Civil Code, which provides a remedy for acts contrary to morals, good customs, or public policy. Exemplary damages were also properly awarded to set a public example and deter similar abuses of authority by public administrators. The Court emphasized that public officials who act with malice and beyond the scope of their duty cannot hide behind their office to evade personal liability for the injury caused.