The Supreme Court ruled that the non-renewal of a professorial lecturer’s appointment does not automatically equate to a dismissal from their position as a member of the Board of Regents. This decision clarifies that a person’s status on the Board is not solely dependent on their continuous employment as a faculty member, particularly when there are allegations of bad faith or ulterior motives behind the non-renewal. The Court emphasized that substantial issues, such as claims for damages due to alleged illegal ouster, must still be resolved even if the injunctive aspect of the case becomes moot.
Faculty Status or Fixed Term: What Constitutes Illegal Ouster from the Board of Regents?
Rafaelito M. Garayblas, a part-time Professorial Lecturer at the Pamantasan ng Lungsod ng Maynila (PLM), was appointed as a member of the Board of Regents representing the PLM faculty. Subsequently, then Manila City Mayor Jose L. Atienza, Jr. appointed Raul I. Goco to the same position. Garayblas filed a Petition for Injunction, arguing that Atienza’s appointment of Goco was illegal since his own term was still valid, and sought damages for what he claimed was his illegal ouster. The Regional Trial Court (RTC) dismissed the petition, stating it lacked jurisdiction and that the case had become moot after Garayblas’s teaching appointment was not renewed. This prompted Garayblas to seek recourse from the Supreme Court, questioning whether the non-renewal of his teaching appointment automatically disqualified him from his position on the Board, and whether the Mayor committed grave abuse of authority.
The Supreme Court addressed whether the present recourse of the petitioner under Rule 45 of the Revised Rules of Court is proper, and whether the court a quo erred in dismissing his petition for injunction on the sole ground that it had been mooted by the non-renewal of his appointment as a Professorial Lecturer at the PLM College of Law. The Court clarified that an issue becomes moot when it no longer presents a justiciable controversy. However, it emphasized that a case should not be dismissed if there are other unresolved issues, especially if dismissing the case would deny the plaintiff due process. Thus, the Court examined the nature of the reliefs sought in the petition for injunction.
In this case, the Supreme Court differentiated between the main action for injunction and the provisional remedy of preliminary injunction, noting that the main action seeks a final judgment, while the preliminary injunction aims to preserve the status quo. Garayblas sought to prevent his removal from the Board and invalidate Goco’s appointment, alleging that these actions were illegal and caused him damages. The Court emphasized that the non-renewal of Garayblas’s appointment as a Professorial Lecturer did not automatically render the petition moot, especially considering his claim that the non-renewal was a tactic to oust him from the Board. It was a matter of policy that the yearly reappointment of professional lecturers in the PLM. The Court needed to assess whether respondents acted in bad faith and whether Goco’s appointment was valid, given that Garayblas was already in the position.
The Supreme Court stated that the issue of the validity of petitioner’s appointment has become moot and academic considering that petitioner’s appointment as member of the Board of Regents expired on August 13, 2004. However, another issue has not been so mooted, that is, the issue of whether petitioner is entitled to moral, exemplary damages, and attorney’s fees because of his alleged illegal ouster as member of the Board of Regents. This is a substantial issue that needs to be resolved by the trial court after trial. The Court cited a few important points on the petition for injunction:
By praying for injunctive relief, petitioner did not intend to correct a wrong of the past, for redress of injury already sustained, but to prevent his ouster from membership in the Board. By his action for injunction, petitioner sought to preserve the status quo of things, to prevent actual or threatened acts which would violate the rules of equity and good conscience as would consequently afford him a cause of action resulting from the failure of the law to provide for an adequate or complete relief.
Furthermore, the Supreme Court cited the arguments of the petitioner. According to Section 4 of R.A. No. 4196, one need not remain to be a member of the faculty after his appointment to the Board of Regents. What the law requires is membership in the faculty roster at the time of appointment and the term of said member being fixed for six (6) years. Hence, the petitioner insisted that his petition for injunction has not been mooted, as he has the right to pursue and regain the position from which he was ousted, and that the case remained justiciable and proper for judicial action. Moreover, there was a continuing violation of his right to security of tenure as a member of the Board of Regents. He reminds the Court that the RTC had issued a Temporary Restraining Order, as well as a writ of preliminary injunction. Furthermore, the court had yet to reconsider his claims for moral and exemplary damages, and attorney’s fees which he had yet to prove during trial.
Building on this principle, the Court emphasized the importance of considering the intent behind the non-renewal of Garayblas’s teaching appointment. If it was indeed a ploy to remove him from the Board, it would constitute a violation of his rights. The Supreme Court underscored that even though Garayblas’s term on the Board had expired by the time the case reached them, his claim for damages resulting from the alleged illegal ouster remained a valid issue that the trial court needed to resolve. This highlights that the expiration of a term does not automatically negate a claim for damages incurred during that term due to unlawful actions.
The Supreme Court’s decision turned on the application of the principle that cases should be decided based on all substantive issues, not just those that become moot. It also addressed the issue of damages and the actions of the respondents and concluded that the case should not have been dismissed. The Supreme Court recognized the trial court’s error in dismissing the petition and the case was remanded for the resolution of the factual and legal issues.
FAQs
| What was the key issue in this case? | The key issue was whether the non-renewal of Rafaelito Garayblas’s teaching appointment at PLM automatically disqualified him from his position as a member of the Board of Regents, and whether he was entitled to damages for alleged illegal ouster. |
| What did the Regional Trial Court decide? | The RTC dismissed Garayblas’s petition for injunction, citing lack of jurisdiction and mootness due to the non-renewal of his teaching appointment. |
| What did the Supreme Court decide? | The Supreme Court reversed the RTC’s decision, holding that the non-renewal of the teaching appointment did not automatically disqualify Garayblas from his Board position, and that his claim for damages remained a valid issue for trial. |
| Was Raul I. Goco’s appointment valid? | The Supreme Court did not definitively rule on the validity of Goco’s appointment but indicated that it was an issue that needed to be resolved by the trial court, particularly concerning whether a vacancy existed when Goco was appointed. |
| What is the significance of the writ of preliminary injunction in this case? | The writ of preliminary injunction issued by the RTC aimed to prevent Garayblas’s ouster from the Board, indicating that the court initially recognized the potential merit of his claim. |
| What happens now that the case is remanded to the trial court? | The trial court must now conduct further proceedings to resolve the issues of bad faith, the validity of Goco’s appointment, and whether Garayblas is entitled to damages for his alleged illegal ouster. |
| Did Garayblas’s term as a member of the Board of Regents expire? | Yes, Garayblas’s term expired on August 13, 2004. However, the expiration of his term did not negate his claim for damages incurred during that term due to unlawful actions. |
| What does security of tenure mean in this context? | Security of tenure, in this context, means that Garayblas had a right to remain in his position as a member of the Board of Regents for the duration of his appointed term unless there was a valid reason for his removal. |
| What is the difference between the main action for injunction and preliminary injunction? | The main action for injunction seeks a final judgment to prevent certain actions, while preliminary injunction is a temporary remedy to preserve the status quo until the case is fully decided. |
In conclusion, the Supreme Court’s decision emphasizes that the non-renewal of a teaching appointment does not automatically equate to a valid removal from a Board of Regents position, especially when bad faith or ulterior motives are alleged. This ruling underscores the importance of thoroughly investigating claims of illegal ouster and ensuring that individuals are not unjustly deprived of their positions and rights. It highlights the significance of examining all relevant factors and issues before dismissing a case, thereby upholding the principles of due process and fairness in legal proceedings.
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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Garayblas v. Atienza, G.R. No. 149493, June 22, 2006