The Supreme Court held that the denial of a sabbatical leave is a privilege, not a right, and absent bad faith, universities have the autonomy to make such decisions. Further, the Court clarified the conditions under which an employee is entitled to back wages when their compensation was withheld due to non-compliance with documentary requirements, while also emphasizing the importance of due process and the principle of damnum absque injuria, where damages without legal injury do not create a cause of action. This ruling emphasizes the necessity of proving bad faith to claim damages and underscores the importance of adhering to institutional procedures.

Navigating Sabbaticals: When Can a University Deny a Professor’s Leave?

The case of Elizabeth L. Diaz v. Georgina R. Encanto, et al. (G.R. No. 171303, January 20, 2016) revolves around Elizabeth Diaz, a long-time associate professor at the University of the Philippines (UP). In 1988, Diaz applied for a sabbatical leave, which was eventually denied. This denial, coupled with the withholding of her salaries, led Diaz to file complaints against several UP officials, alleging conspiracy and violation of her rights. The central legal question is whether the UP officials acted in bad faith when they denied Diaz’s sabbatical leave application and withheld her salaries, thereby entitling her to damages under Articles 19 and 20 of the Civil Code.

Diaz argued that the denial of her sabbatical leave and the subsequent withholding of her salaries were acts of bad faith by UP officials. She sought damages, claiming that these actions constituted a tortious act under Philippine law. The Regional Trial Court (RTC) initially ruled in her favor, finding that the delay in resolving her sabbatical leave application was unreasonable. However, the Court of Appeals (CA) reversed this decision, finding no negligence or bad faith on the part of the respondents. This divergence in findings led Diaz to elevate the case to the Supreme Court.

The Supreme Court scrutinized the concept of abuse of rights under Article 19 of the Civil Code, which states:

Art. 19. Every person must, in the exercise of his rights and in the performance of his duties, act with justice, give everyone his due, and observe honesty and good faith.

The Court emphasized that bad faith is the core of Article 19, involving a dishonest purpose or some moral obloquy and conscious doing of a wrong. Good faith, on the other hand, is presumed, and the burden of proving bad faith lies with the party alleging it. The Court also cited Article 20 of the Civil Code:

Art. 20. Every person who, contrary to law, willfully or negligently causes damage to another, shall indemnify the latter for the same.

The Court reiterated that malice or bad faith is not simply bad judgment or simple negligence; it involves a dishonest purpose or some moral obloquy and conscious doing of a wrong, a breach of known duty due to some motives or interest or ill will that partakes of the nature of fraud. It implies an intention to do ulterior and unjustifiable harm. To succeed in her claim, Diaz needed to demonstrate that the respondents acted with such malice or bad faith.

The Court highlighted that a sabbatical leave is a privilege, not a right, and its grant is subject to the exigencies of the service. This principle underscores the university’s autonomy in managing its academic affairs. Furthermore, the Court noted that the Ombudsman had previously dismissed Diaz’s complaint for lack of merit, finding no manifest partiality, evident bad faith, or gross inexcusable negligence on the part of the respondents. This finding was crucial as it indicated that the UP officials’ actions were not driven by malicious intent but by the requirements of their positions.

The Court also considered the prior rulings of the Ombudsman and the Court of Appeals, both of which found no evidence of bad faith on the part of the UP officials. These consistent findings weighed heavily in the Supreme Court’s decision. The Court found no reason to disregard these prior findings, especially given that its own review of the evidence revealed no traces of bad faith or malice in the respondents’ denial of Diaz’s sabbatical leave application. The denial was based on the recommendation of Dean Encanto, who was in the best position to assess the needs of the College of Mass Communication.

Moreover, the Court addressed the issue of the delay in resolving Diaz’s sabbatical leave application. While the RTC initially awarded damages for the unreasonable delay, the Supreme Court clarified that the delay alone did not constitute bad faith. Diaz failed to prove that the respondents purposely delayed the resolution of her application to prejudice her. Any delay that occurred was due to the fact that Diaz’s application did not follow the usual procedure, causing the processing to take longer.

Regarding the withholding of Diaz’s salaries, the Court acknowledged that she was not paid for the first semester of Academic Year 1988-1989 because she did not teach during that period. However, the Court also found that Diaz’s name was removed from the final schedule of teaching assignments without her prior knowledge or consent. As such, the Court deemed it fair that Diaz be entitled to her salary for that semester, while her sabbatical leave application was still pending. This decision reflects the Court’s consideration of equity and fairness in the application of the law.

For the subsequent periods, the Court sided with the respondents, finding that Diaz’s refusal to comply with the documentary requirements of UP justified the withholding of her salaries. The Court emphasized that employees must adhere to institutional procedures to be entitled to compensation. Nevertheless, since Diaz had rendered services to UP during these periods, she was entitled to compensation upon submission of the required documents.

The Supreme Court emphasized that because the respondents did not abuse their rights, they could not be held liable for damages. The Court invoked the principle of damnum absque injuria, which means that damages resulting from an act that does not amount to a legal wrong do not afford a remedy. The Court also denied Diaz’s claim for attorney’s fees, as there was no sufficient showing of bad faith on the part of the respondents.

The Court, citing Nacar v. Gallery Frames, clarified that the applicable rate of legal interest on Diaz’s withheld salaries would be 6% per annum. This interest would be applied from April 17, 1996, the date of the RTC’s decision, until the salaries were fully paid. This clarification ensures that Diaz receives fair compensation for the delay in the payment of her salaries.

FAQs

What was the key issue in this case?	The key issue was whether the UP officials acted in bad faith by denying Diaz’s sabbatical leave application and withholding her salaries, thereby entitling her to damages under Articles 19 and 20 of the Civil Code.
Is a sabbatical leave a right or a privilege?	The Supreme Court clarified that a sabbatical leave is a privilege, not a right, and its grant is subject to the exigencies of the service. This means that the university has the discretion to deny a sabbatical leave based on its needs and priorities.
What is the meaning of damnum absque injuria?	Damnum absque injuria means damage without legal injury. It implies that damages resulting from an act that does not amount to a legal wrong do not afford a remedy under the law.
What is the required legal interest on the unpaid salaries?	The Court cited Nacar v. Gallery Frames and clarified that the applicable rate of legal interest on Diaz’s withheld salaries would be 6% per annum. This interest would be applied from April 17, 1996, the date of the RTC’s decision, until the salaries were fully paid.
What must an employee prove to claim damages for abuse of rights?	Under Article 19 of the Civil Code, an employee must prove that the employer acted in bad faith with the sole intent of prejudicing or injuring them when exercising their rights or performing their duties.
Why were Diaz’s salaries withheld?	Diaz’s salaries were withheld because she did not teach during the first semester of Academic Year 1988-1989, and later, because she refused to comply with the documentary requirements of UP, specifically the Report for Duty Form.
What is the significance of the Ombudsman’s findings in this case?	The Ombudsman’s finding of no manifest partiality, evident bad faith, or gross inexcusable negligence on the part of the UP officials was crucial. It indicated that their actions were not driven by malicious intent but by the requirements of their positions.
What was the basis for the Court’s decision to award Diaz her salary for one semester?	The Court awarded Diaz her salary for the first semester of Academic Year 1988-1989 because her name was removed from the final schedule of teaching assignments without her prior knowledge or consent. This decision reflects the Court’s consideration of equity and fairness in the application of the law.

In conclusion, the Supreme Court’s decision in Diaz v. Encanto reaffirms the principle that the grant of a sabbatical leave is a privilege, not a right, and that universities have the autonomy to make such decisions absent bad faith. The ruling underscores the importance of adhering to institutional procedures and the necessity of proving bad faith to claim damages for abuse of rights. It also highlights the concept of damnum absque injuria, where damages without legal injury do not create a cause of action.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

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: Elizabeth L. Diaz, vs. Georgina R. Encanto, G.R. No. 171303, January 20, 2016